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Program Registration

Physician and Teaching Hospital Registration in the Open Payments System
Physicians and teaching hospital representatives can register in Open Payments system. Visit the
Physician page or Teaching Hospital page for more information.

Physicians can look up their National Provider Identifier (NPI) on the National Plan & Provider Enumeration System website and use the Taxonomy Crosswalk document, also available in the Related Links section at the bottom of this page, to look up specialty codes.

Important Updated Resource for ALL Open Payments System Users:
The
Open Payments User Guide has been extensively updated and is now available to provide industry, physicians, and teaching hospitals with a comprehensive understanding of Open Payments system and requirements. A new chapter has been added on how a physician and teaching hospital can register in the Open Payments system.  It can also be downloaded on the Open Payments Fact Sheets and User Guides web page.

CMS developed two Quick Reference Guides: how a physician can register in the Open Payments system and how a teaching hospital representative can register in the Open Payments system

 

As a reminder, Open Payments (the Sunshine Act) requires that all applicable manufacturers and applicable GPOs report information about payments or other transfers of value and ownership and investment interests they've made to physicians or teaching hospitals to CMS. As a result, physicians and teaching hospitals are encouraged to register with the Open Payments system so that they are able to review data submitted by these companies to ensure it is accurate and complete, and if not, dispute the information. When a dispute occurs, the physician or teaching hospital will be able to work with applicable manufacturers and applicable GPOs to make any necessary corrections to the information before CMS releases those data to the public.

 

Physicians and Teaching Hospitals: Important Information Regarding Registration for the 2013 Open Payments Program Year Going on Now!
 

Physicians and teaching hospital representatives are encouraged to register in CMS’ Enterprise Portal (Enterprise Identification Management system – EIDM) and in the Open Payments system in order to view the data reported by industry that will be made public on September 30, 2014. Registration is a voluntary process, but it is required in order to review and dispute data reported by the industry that a physician or teaching hospital representative believes to be inaccurate or incomplete.
 

Registration for physicians and teaching hospitals will be conducted in two phases for this first Open Payments reporting year:

    Phase 1:

    Phase 2:

Review & Dispute – Now through September 10, 2014: For 45 days immediately following the initial availability of the Open Payments system, review and dispute data submitted by industry.  If you have any concerns about the data’s accuracy, this is the time to dispute and correct the data.

Note: Any data that is disputed, if not corrected by industry, will still be made public but will be marked as disputed. Learn more about the review and dispute process here.

Industry: Registration and Data Submission for the 2013 Open Payments Program Year 

 

On February 18, Open Payments registration and data submission for applicable manufacturers and applicable GPOs opened with Phase 1 of a two-phased approach:

 

  • Phase 1 (closed; conducted February 18 through March 31, 2014): Included user registration for applicable manufacturer and applicable GPO authorized officials in the CMS Enterprise Portal (the gateway to CMS' Enterprise Identity Management system (EIDM)), submission of corporate profile information, and aggregate information about their 2013 payment or other transfer of value and ownership/investment interest data. For more information on the instructions provided for Phase 1, review the steps to complete EIDM registration and the Phase 1 Instructions and Learning Resources document.
  • Phase 2 (closed; conducted June 1 through June 30, 2014): Occurred in two steps to facilitate file testing and final submissions for applicable manufacturers and applicable GPOs.
    • Step 1: Authorized officials of applicable manufacturers and applicable GPOs were required to:
      • Complete Open Payments system registration for themselves and their reporting entity;
      • Confirm the accuracy of the reporting entity profile data submitted for Phase 1; and
      • Delegate roles and responsibilities by nominating system users to fill specific user roles.

During this period, system users in the role of submitter:

  • Performed test file uploads and submitted data files to validate the file structure and contents of the file (for more detail on this process, review the Phase 2 Instructions document); and
  • Utilized the error report produced by the Open Payments system to fix any data errors (if any) in submitted files, along with the Error Code File document, which provided descriptions of the error code, the corresponding data element, and steps to avoid and correct each error, to fix any data errors (if any) in submitted files.

When the test data files were successfully uploaded and validated at this step, industry users were able to move on to Step 2.

    • Step 2: closed, conducted June 9 through June 30, 2014, the Open Payments system allowed:  
      • Submitters to perform final data submission (which included a series of checks to match the reported data to the appropriate physicians and teaching hospitals); and
      • Attesters to attest to the accuracy of their submitted detailed 2013 payment or other transfer of value data, or ownership/investment interest data.

All Phase 2 activities (Steps 1 and 2) were completed by June 30. Review the Phase 2 Instructions document for a detailed guide to Phase 2 timing and activities (this document is also available on the Data Submission and Attestation page of the Open Payments website).  

Registration and Data Submission Resources for Industry
 

Video Tutorials: Three educational tutorials are available, addressing data submission resources, system registration, and data submission and attestation. Specifically, these tutorials cover the following material:

Phase 2 CSV & XML Tutorial: Preparing Data Files for Submission: How to prepare data submissions using the data submission resources that have been newly updated.
Phase 2 Registration Demo: How to register in the Open Payments system, explained through step-by-step screenshots.
Phase 2 Data Submission Demo: How to formally submit data files in the acceptable file formats to the Open Payments system, and attest to the accuracy of the data.

 

See the below table for a summary of the registration requirements and timeline. For additional registration details, review the Open Payments User Guide.

Registration
  Applicable Manufacturers Applicable GPOs Physicians Teaching Hospitals
Who registers with CMS? Yes, but only if there is data that has to be reported for the program cycle Yes, but only if there is data that has to be reported for the program cycle Optional, not required.  Registering allows data to be seen and corrected before it is publicly posted.   Optional, not required.  Registering allows data to be seen and corrected before it is publicly posted.  
When does the Open Payments system open for registration for the 2013 program cycle?

Phase 1 registration was conducted from February 18 through March 31, 2014. Phase 2 registration began June 1, 2014.

Phase 1 registration was conducted from February 18 through March 31, 2014. Phase 2 registration began June 1, 2014.

Phase 1 registration began June 1, 2014. Phase 2 registration began July 14, 2014.

Phase 1 registration began June 1, 2014. Phase 2 registration began July 14, 2014.

 

When does the Open Payments system close for registration for the 2013 program cycle? Once the system is open for applicable manufacturer registration, there is no deadline for registration. Once the system is open for applicable GPO registration, there is no deadline for registration.

Once the system is open for physician registration, there is no deadline for physician registration. 

Once the system is open for teaching hospital registration, there is no deadline for teaching hospital registration.

When does the Open Payments system open for registration for on-going program cycles? January 1 January 1

Once the system is open for physician registration, there is no start date for physician registration in subsequent years; registration can be ongoing.

Once the system is open for teaching hospital registration, there is no start date for teaching hospital registration in subsequent years; registration can be ongoing.

When does the Open Payments system close for registration for on-going program cycles? March 31 March 31

Once the system is open for physician registration, there is no end date for physician registration in subsequent years; registration can be ongoing.

Once the system is open for teaching hospital registration, there is no end date for teaching hospital registration in subsequent years; registration can be ongoing.

Additional Notes The registration and identity vetting process may take up to a week to complete, so it is advised that individuals representing Applicable Manufacturers register as soon as possible in order to avoid delays in data submission. The registration and identity vetting process may take up to a week to complete, so it is advised that individuals representing Applicable Manufacturers register as soon as possible in order to avoid delays in data submission. Registration that occurs beyond the review and dispute period does not guarantee that any changes can be made to inaccurate data being displayed. Registration that occurs beyond the review and dispute period does not guarantee that any changes can be made to inaccurate data being displayed.