As previously reported, the Centers for Medicare and Medicaid Services (CMS) has adopted a two-phased approach for registration and submission of Sunshine Act* data for the 2013 reporting year. Phase 1 of CMS' Open Payments registration and data submission for applicable manufacturers and applicable group purchasing organizations (GPOs) began on February 18, 2014, and concluded on March 31, 2014. Phase 2 is scheduled to begin late May/June 2014, and will run for no fewer than 30 days. During Phase 2, CMS will require applicable manufacturers and applicable GPOs to submit detailed 2013 payment data, and legal attestation to the accuracy of the data.

In an effort to prepare applicable manufacturers and applicable GPOs for Phase 2, CMS previously indicated that it is developing a series of educational tutorial videos. CMS has announced that the first video is now available. This tutorial explains how to prepare data submissions using its data submission resources, including the CSV and XML Sample Files, and the XSD Document. This tutorial is available on the Open Payments website in the "Data Submission and Attestation" section.

CMS has also indicated that it will release additional educational tutorial videos, which will focus on the following topic:

  • How to register in the Open Payments system, explained through step-by-step screenshots; and
  • How to formally submit data files in the acceptable file formats to the Open Payments system, and attest to the accuracy of the data.

Please note that this two-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 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.