Aggregate Spend Reporting Update: Open Payments Registration & Submission

By Ben Carmel

Friday afternoon’s email from CMS proved to be an interesting one. While reconfirming their commitment to transparency, the email blast answered some outstanding questions about registration, but sparked some new debate around data submission.

Simply put, CMS has outlined a new, two-phased approach to data submission and provided a date for registration availability.

Phase 1 of the process includes registration and an aggregated data submission.

  • The opening of the system for CMS Enterprise Portal registration & submission of corporate profile information is set to take place on Tuesday, February 18th
    • Registration in general, looks unchanged from previous communications
  • After registration is complete, the authorized user will be provided with the authority to delegate submission responsibilities to others and details on a new data submission process
    • This process will require some level of aggregated data across the organization
    • Details of this new submission will only be made available to users after their CMS registration has completed
    • Final submission of this data and corporate profile information must take place by March 31st

Phase 2 of the process will contain the full detailed data submission that everyone had been working to complete by the end of March.

  • The second data submission should be identical to the detailed submissions for General Payments, Research Payments and Physician Ownership that everyone has been completing
  • The timing is vague, with a start to the submission process in May and a deadline for submission no earlier than 30 days from that point
  • Final submission must be completed no later than August 1st
  • Given all of this, companies should be targeting a detailed submission and attestation at the end of May/beginning of June

The updated CMS page discussing the phases can be located here.

CMS will announce a date for a webinar this week in an effort to clarify last week’s email, but there is no word on this yet. Hopefully, it will come before next Tuesday’s start in registration. There has also not been any further clarification on the phases; for example, how manufacturers should handle overall data value changes between the Phase 1 aggregate submission and the Phase 2 detailed submission.

Stay tuned for further details as they come from CMS and as we begin the registration process next week.