Looking back on week 1 of the CMS Aggregate Spend data submission

By Ben Carmel

With Week 1 of the CMS Open Payments data submission almost complete, Polaris takes a look at how we spent our week.


CMS Aggregate SpendHopefully everyone has been busy registering and submitting/reviewing data with CMS this week, and now that the first week is coming to a close, the Polaris team wanted to share some quick observations from across our client base.

Our top 10 observations from CMS data submission week 1:

1. Make sure you remember those secret password questions, as passwords expire every 60 days, and anyone that hasn’t logged in since Phase 1 registration will need to reset their password2. Every physician you submit requires a taxonomy code

  • This was a big surprise as most companies filled out taxonomy only for individuals with an NPI
  • Options include matching corporate specialties for non-NPI individuals to the taxonomy cross walk or defaulting to 208D00000X (Physician/Undefined Physician type)

3. The test upload button does nothing at this point, don’t even bother clicking it
4. Double check your submission files that were developed earlier have been updated to reflect your new Registration ID
5. Watch out for special characters, most fields don’t like characters outside of letters and numbers
6. Make sure that if a PI is also the covered recipient that you duplicate their information in the PI fields as well as the covered recipient fields
7. Make sure your NDC codes are 10 digits without hyphens or 12 with hyphens
8. Beware of field validations and field lengths, make sure those zip codes are all 5 or 9 digits in total
9. Once your data validation issues are resolved, make sure to click the “final” submission so CMS can perform the match/merge process

  • Final does not always mean final, at least in this case

10. Stay calm when repeating your name, phone number and email each time you call the CMS helpdesk

As everyone works towards the June 30th deadline to register, submit, validate and attest, Polaris will continue to provide updates.

For further clarification or additional details on CMS filing or to discuss specifically the impact of this filing for your company, please contact Ben Carmel or Alice Dong or email us at Polaris Aggregate Spend.