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.
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
|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.||
|Attester||A person who will attest to the accuracy of the data that has been submitted for the applicable manufacturer or applicable GPO.||
You can learn more about the user roles and the nomination process by visiting the Resources page.