User Roles

Program Expansion

Applicable Manufacturers and Group Purchasing Organizations should be aware of changes that became effective when Open Payments expanded on January 1, 2021.

Learn more on the Changes for Reporting Entities page.

User Roles for Applicable Manufacturers and GPOs

The three user roles for applicable manufacturers and GPOs are Officer, Submitter, and Attester. Applicable manufacturers and GPOs must have individuals assigned to these roles within the Open Payments system to perform specific functions. An applicable manufacturer or GPO:

  • Must have at least one officer identified; each user can hold multiple user roles
  • Can have a total of 10 users, with no more than 5 of those users holding an officer role

To make registration easier, an applicable manufacturer or GPO will want to determine the appropriate individual to fill each of these roles prior to registering.

The person registering your organization must select the role of officer. He or she may also select the role of submitter and/or attester for him or herself or choose others for these roles. At least one person must be identified for each of the three roles in the Open Payments system during initial registration, whether it is the individual registering in all three roles or others that he or she chooses. The system won’t allow you to proceed without at least one person chosen for each user role.

More information about the functions and requirements of each role is outlined in the table below.

User Role Description Functions Requirements
Officer

A person who will manage the applicable manufacturer or GPO in the Open Payments system, and manage all user roles associated with the entity.

The officer should be an executive level employee such as a Chief Executive Officer, Chief Financial Officer, Chief Compliance Officer, or other equivalent position
  •  Manage the reporting entity’s profile in the Open Payments system
  • Nominate (approve) other individuals for submitter, attester, and officer roles
  • May also self-select the role of submitter and/or attester
  • Must be an officer as designated by the applicable manufacturer or applicable GPO
  • If nominated, must either accept or reject the nomination
  • Must select the role of officer when registering a new applicable manufacturer or GPO. Registration will not proceed if this role is not selected
Submitter A person who will submit data on payments, other transfers of value, and/or ownership and investment interests for the applicable manufacturer or GPO. The submitter will also receive all notifications of disputed data.
  •  Submit data in the Open Payments system on behalf of the applicable manufacturer or applicable GPO
  • May edit payments or other transfers of value and ownership/investment interests submitted to the Open Payments system
  • Receives emails regarding data disputed by physicians and teaching hospitals
  • Not required to be an officer of the applicable manufacturer or applicable GPO
  • If nominated, must either accept or reject the nomination
Attester A person who will attest to the accuracy of the data that has been submitted for the applicable manufacturer or applicable GPO.
  • Attest to accuracy of the data in the Open Payments system on behalf of the applicable manufacturer or applicable GPO
  • Must be an officer of the applicable manufacturer or applicable GPO as required
  • If nominated, must either accept or reject the nomination

You can learn more about the user roles and the nomination process by visiting the Resources page.
Page Last Modified:
09/06/2023 04:51 PM
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