Life Science Compliance Update

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May 02, 2014

Physician Payments Sunshine Act: Phase 2 of Open Payments Registration and Data Submission

CMS sent out yet another announcement that they expect to begin Phase 2 of Open Payments registration and data submission for industry in "late May/June 2014." CMS states that Phase 2 will run for no fewer than 30 days. More information would be coming in the next few weeks.

Phase 2 will be more labor intensive than Phase 1. The authorized officials from applicable manufacturers and GPOs will need to complete the following actions once Phase 2 begins:

  • Log into the Open Payments System using their CMS user ID (created in Phase 1), and complete Open Payments registration for the entity and for themselves as authorized officials (they will need to provide information within the Open Payments system to supplement what was submitted for Phase 1);
  • Authorized officials who did not register in CMS' Enterprise Portal in Phase 1 must complete that registration in order to access the Open Payments System in Phase 2. Review the Program Registration page of the Open Payments website for step-by-step screenshot instructions to guide users through the CMS Enterprise Portal registration process.
  • Confirm the accuracy of the entity profile data submitted for Phase 1, which will be pre-populated in the Open Payments system for Phase 2; and
  • Upload or enter, submit, and attest to the accuracy of the detailed 2013 payment or other transfer of value data, or ownership/investment interest data.

In addition, in Phase 2, authorized officials will be able to delegate roles and responsibilities within the Open Payments system by nominating other individuals to fill specific user roles. These individuals may then perform the required actions associated with their user role, such as submitting and attesting to the data for the 2013 program year.

CMS stated that they are also developing a series of tutorial videos to explain the following topics:

  • How to prepare data submissions using the data submission resources, specifically, using the CSV and XML Sample Files and XML Schema Definition (XSD document) to format data for upload into the Open Payments system.
  • How to register in the Open Payments system, explained through step-by-step screenshots.
  • How to formally submit data files in the acceptable file formats to the Open Payments system, and attest to the accuracy of the data.

Click here for which highlighted the responsibilities for Phase 1 and Phase 2 in a comparison chart.


We have heard CMS state for the last month that Phase II information is forthcoming in the next few weeks.

We recently asked a large group of manufacturers, and no one was aware of any pre-testing with actual data of the CMS system. There may be some glitches with the first uploads. Because of potentially large files, up to 2.0 gigabytes online, uploads may take several hours and may be interrupted. So give yourselves plenty of time.

It is important for applicable manufacturers, GPOs and distributors who have not yet registered for Open Payments to register with CMS. The process takes at least two weeks for CMS to verify your organization and some of the companies who registered late in Phase 1 did not receive their login information in time.


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