In an effort to assist reporting entities with Phase 1 registration and data submission, the Centers for Medicare and Medicaid Services (CMS) has posted on its Open Payments website a new table that provides a side-by-side comparison of Phases 1 and 2. Some of the topics covered in the comparison chart are:

  • Registration procedures for entities located outside the United States;
  • Information regarding the Remote Identity Proofing (RIDP) Process;
  • User roles that are available in the Open Payments system;
  • Information on how to handle registration for multiple entities;
  • Data submission instructions;
  • Assumption documents; and
  • The attestation process.

Additionally, CMS has updated its Data Submission Instructions Document to include the following:

  • Step-by-step screenshot instructions for creating a pipe-delimited CSV file in Microsoft Excel 2010;
  • Specified categories to be used when entering registering entity business type;
  • Specified required and optional data fields; and
  • An example of how to enter aggregate data, using a payment or transfer of value scenario.

Phase 1 of the registration and data submission process will end on March 31, 2014. CMS has indicated that for the 2013 reporting year it will not enforce penalties for reporting non-compliance until after the close of Phase 2 registration and data submission. CMS has also indicated that it will announce additional information in the spring of 2014 regarding the review and correction phase, which is scheduled to begin on August 1, 2014. Please note that this phased approach to Open Payments registration and data submission is only for the 2013 reporting year, which includes data that was collected between August 1 and December 31, 2013.

CMS encourages industry users to review the data registration and submission resources and contact the help desk at with any follow-up questions.