Open Payments Changes for Reporting Entities

Open Payments Changes for Reporting Entities

Open Payments program expansion is in effect! Here's what reporting entities should know.

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Effective January 1, 2021, the Open Payments definition of a covered recipient expanded to include five new provider types:
  • Physician Assistants
  • Nurse Practitioners
  • Clinical Nurse Specialists
  • Certified Registered Nurse Anesthetists (Including Anesthesiologist Assistants)
  • Certified Nurse Midwives
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The Nature of Payment categories are updated to include three new Natures of Payment:
  • Debt Forgiveness
  • Long term medical supply or device loan
  • Acquisitions

Consolidated education categories: The accredited/certified and unaccredited/non-certified continuing education program categories are combined into one, “Compensation for serving as faculty or as a speaker for a medical education program.”

Note: The changes to the Nature of Payment categories will be available within the Open Payments System when submitting records dated on or after January 1, 2021. The Natures of Payment updates are not applicable to Program Year 2020 data submission.

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Device Reporting Requirements:
  • Added reporting requirements for the ‘device identifier’ component of the unique device identifier for medical supplies and devices
What does this mean for reporting entities?

If you are a reporting entity, you will need to collect and submit data related to payments or transfers of value between you and these five new provider types as well as physicians and teaching hospitals.

Reporting entities will be required to submit this data to CMS beginning in 2022, which means data collection on these interactions began on January 1, 2021.

The data collected in 2021 will be reported and published in 2022.

You can read the Final Rule for a full look at the program policies and regulations.


We know that reporting entities may have questions about these changes and the 2021 data collection cycle. The following resources are designed to help you as you collect data throughout 2021. We will post more here as they are made available so stay connected with us for updates!

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Device Validation Resources

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Newly Added Covered Recipient Expansion Resources

  • PY 2021 Onwards – Submission Data Mapping Document (XLSX)
    A spreadsheet that provides an explanation of each data element in the Open Payments system and shows the corresponding field name in the CSV sample files. This includes updated definitions and validation rules for the newly added covered recipient types.
  • PY 2021 Onwards – Change Summary Document (PDF)
    This resource lists the changes made to the Submission Data Mapping and/or CSV templates (also known as the sample files) for Program Years 2021 and onwards compared to the Program Year 2016-2020 Submission Data Mapping Document/CSV templates. This resources helps to quickly identify the upcoming changes to the reporting templates.
  • Sample Files for PY 2021 Onwards
    There are general and research sample files prepared for Program Year 2021 data collection. These sample files are updated per the device validation reporting requirements and the covered recipient expansion. There are no changes to the Ownership reporting sample files.
    General Sample Files (CSV)
    Research Sample Files (CSV)
  • Expansion of Covered Recipients, Validating and Standardizing Medical Devices, & Natures of Payments (PDF)
    A high-level overview of how Non-Physician Practitioners are introduced in to the Open Payments program, how the Open Payments system validates medical devices and medical supplies, and understand the updated information on Nature of Payment categories.
  • Covered Recipient Definition Expansion FAQs (PDF)
    Includes a selection of frequently asked questions and CMS answers about the Covered Recipient definition expansion.
  • Open Payments Overview Handout (PDF)
    A one-page resource to provide an overview of the Open Payments program.  Reporting entities may find this helpful when interacting with covered recipients.
  • Program Year 2022 Physician and Non-Physician Practitioner Taxonomy List (XLSX) (XLSX)
    This resource contains the full set of taxonomies for Open Payments reporting of Program Year 2022 including taxonomy codes for physician covered recipients and the new provider types.
  • Preliminary Non-Physician Practitioner List (PnPPL)
    The PnPPL is designed to help reporting entities collect and validate Non-Physician Practitioner and Principal Investigator identifying information before reporting to the Open Payments system. Please note, the PnPPL is accessible via the Open Payments System. Log in and select the ‘submission’ tab and view the documents on the right-hand side of the page.
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Page Last Modified:
01/05/2024 06:31 AM