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Data Submission and Attestation


Data Submission and Attestation for Applicable Manufacturers and GPOs

To meet the requirements of Open Payments, authorized officials from applicable manufacturers and GPOs are required to submit final payment or other transfer of value data or ownership/investment interest data, and attest to the accuracy of that data. Once the final data is submitted, the Open Payments system will match the records you submit with physician and teaching hospital profiles. If the system is not able to match any of the data, you’ll be notified and have the opportunity to correct and re-submit the final data. Reporting under the Open Payments system is not considered complete until the official attestation is received.

How do you submit data?

We require applicable manufacturers and GPOs to submit Open Payments data by March 31 each year.
The Open Payments system provides the following options for data entry and submission:

  • Manual data entry via the Open Payments system
  • Bulk data entry via CSV file uploads
  • Maximum file size for bulk uploads is 250MB
  • Files larger than 250MB need to be separated into multiple files

System users who are “submitters” will be able to:

  1. Upload and submit a test file to validate that the data file is formatted correctly.
  2. Use the error report produced by the Open Payments system to correct any data errors in the file.

For detailed instructions and screenshots that provide step-by-step instructions on how to submit the data, refer to the Resources page.  

How do you attest to the data?

Once records have been submitted as final, the attestation process begins. First, you’re able to add assumptions to the attestation. This information explains reasonable assumptions made and the methodologies used when reporting payments or other transfers of value or ownership or investment interests. For example, you may use this area to show how they calculated the cost of an individual meal or a reprint.

After adding assumptions, you must attest to the timeliness, accuracy and completeness of all submitted data including any re-submissions of corrected data. The most recent, attested data will be considered the final submission. Only data that has been attested to will be considered as reported. You may review the attestation language here. You will not be able to make changes to this language. After you attest, the records will reflect that the payments are attested to.

For additional information on attestation, please visit the Resources page.