The Open Payments Program Year 2025 data submission opened on February 1, 2026, and closes on March 31, 2026. Applicable manufacturers and group purchasing organizations (GPOs) (collectively referred to as reporting entities) should begin submitting Program Year 2025 data.
All data submission activities are completed within the Open Payments System. Registration in the Open Payments System is required to submit data to CMS. If your organization is already registered, please remember to recertify; yearly recertification is required for entities with reportable data. If you have not accessed your account in the last 180 days, you will need to call the Open Payments Help Desk to reactivate your account.
For Program Year 2025 reporting to be considered timely, the data must be submitted and attested by March 31, 2026. Any record(s) submitted or attested after the deadline are considered late and therefore noncompliant with program requirements. Noncompliant records may result in civil monetary penalties.
CMS recommends completing the submission process as early as possible in the submission window to avoid potential slower system responses at the end of the submission window, as this will not constitute a valid mitigating circumstance for a late submission.
The Open Payments system no longer accepts records for Program Years 2013 through 2019.
(Back to top)
All reporting entities should review and if needed, update their contact information. Accurate contact information is required by program regulations and ensures that your organization receives all important program and compliance related communications.
Contact information includes a mailing address, email address, and at least two points of contact within the organization. Without the correct contact information, your organization may not receive crucial information about potentially inaccurate, untimely, or incomplete records. Not receiving compliance notices due to out-of-date contact information is not a mitigating circumstance for failing to comply and any civil monetary penalties that may result.
Contact information must be kept current for at least two years following record submission, even if the reporting entity does not submit records for subsequent program years.
(Back to top)
Data Submission Suggestions:
The following suggestions may be helpful for meeting the requirements for timely, accurate, and complete reporting to Open Payments.
Review Content
Remember to verify your data for accuracy before finalizing your submission.
While submitted information may meet the requirements for data type, format, and field size, that does not necessarily mean that the contents of the fields are valid. Simple errors such as misspellings can lead to failed record validation and delay the submission process.
- When submitting General Payment records, remember to select an appropriate Nature of Payment category. More information and guidance is available on the Natures of Payment page.
- Use the Contextual Information field to include additional information. The information included in this context field is included in the public data set.
- Use the assumptions statement to explain any methodologies used for selecting nature of payment categories. This statement is not published and is used to explain any methodologies or unusual submissions to CMS, especially for topics such as ownership and investment interest valuation, record deletion, and resubmission.
Submit Early
CMS recommends beginning the reporting process early to allow time for addressing any errors or issues. Starting early helps to avoid longer upload times that may occur towards the end of the submission window when the system is used most heavily. If records fail validation, it may take additional time to edit and resubmit. Reporting entities should plan accordingly because late attestation due to failed validation or slow processing times are not exemptions to the requirement for timely reporting.
Data Submission Resources It is recommended that you have the most recent versions of the Open Payments resources, including but not limited to: Open Payments User Guide for Reporting Entities, Data Submission Mapping Document, and the Error Code Key document. Below are a few key resources designed to support Open Payments reporting requirements.
-
Validated Physician List (VPL) and Validated Non-Physician Practitioner List (VNPPL): These validated lists are designed to minimize matching errors during data submission and help eliminate inconsistencies in the data. These lists are for reference and are not a complete list of individuals who are considered covered recipients under the Open Payments program. An individual’s absence from these lists does not mean that payments to them do not have to be reported. You must be registered in the Open Payments system and affiliated with a reporting entity to access and download the VPL, NPPL, and the accompanying instructions documents.
The following resources are available on the Open Payments Resources for Reporting Entities Page:
-
PY 2023 and Onwards Submission Mapping Document: This document serves as a data dictionary for the three types of reports (General, Research, and Ownership/ Investment Interest) submitted to Open Payments. This version should be used for data collection and submission for Program Year 2023 to present. It provides specifications for reporting data on the newly added covered recipient types, updated device reporting requirements and updated nature of payment categories.
-
PY2023 and Onwards Sample Submission CSV Files: These files can be used to check formatting of data submitted through bulk file uploads. Please note that for both general and research payments, there are multiple versions of the Sample Submission CSV files depending on the reporting year.
-
Open Payments Physician and Non-Physician Practitioner Taxonomy Code List: This list has all the accepted taxonomy codes and can be used to report physician and non-physician practitioner specialties. If a covered recipient’s National Plan and Provider Enumeration System (NPPES) profile does not contain any of the specialties on the Open Payments Physician and Non-Physician Practitioner Taxonomy Code List, the reporting entity may provide an alternative code from that list.
-
2025 Reporting Cycle Teaching Hospital List: A list of all teaching hospitals that are reportable for the purposes of Open Payments for Program Year 2025.
-
Preliminary Medical Device and Medical Supply Reference Data: This preliminary reference data includes medical device and medical supply names and Primary Device Identifier Information for all the medical device and medical supplies listed in the Food and Drug Administration (FDA) Global Unique Device Identification Database Directory (GUDID) through December 31, 2025. This dataset is preliminary and provided to support Program Year 2025 data collection. An active list of devices is located on the Access GUDID website at https://accessgudid.nlm.nih.gov/download. An instructions document is available, which provides details about the use of the Device Name and Primary Device Identifier (PDI) dataset.
(Back to top)
Submit questions to the Help Desk via email at openpayments@cms.hhs.gov or by calling 1-855-326-8366 (TTY Line: 1-844-649-2766).
The Open Payments Help Desk is open from 9:00am – 5:00pm (ET) Monday through Friday, excluding federal holidays.
The Help Desk refers media inquiries to CMS’ Press Office for response.
(Back to top)
Creating Public Transparency of Industry-Provider Financial Relationships.
|
