CMS Releases New Open Payments FAQs For Data Submission: Highlight New Matching Process, Renewing Delay In Publication

 Today, the Centers for Medicare and Medicaid Services (CMS) released five new operational FAQs that can help stakeholders working towards their data submission. As a reminder, CMS will be hosting a call tomorrow for Q&As related to registration, data submission, and attestation.

“NEW” Why am I receiving a “Failed Matching Validation” message for payment records that were accepted last year?

Payment records that were successfully matched in 2014 may now appear as “Failed Matching Validation” in 2015 because all records are now subject to a more stringent matching process that was implemented in early 2015. These records will need to be reviewed and corrected. For additional guidance, refer to the Open Payments System Quick Reference Guide: Identifying and Correcting Validation and Matching Errors located on the Resources page of the Open Payments website.

After consulting this resource, if you are having trouble moving your records out of “Failed Matching Validation” status, contact the CMS Open Payments Help Desk at openpayments@cms.hhs.gov or 1-855-326-8366 for assistance.

“NEW” How do I re-new a record’s delay in publication status?

Payment records may be delayed in publication if the payment or other transfer of value is related to:

• Research or development of a new drug, device, biological, or medical supply;
• Research or development of a new application of an existing drug, device, biological, or medical supply; or
• Clinical investigations regarding a new drug, device, biological, or medical supply.

Payment records can be delayed in publication for up to four years after the date of payment. The request for a delay must be renewed each year. If this request is not renewed each year by the end of the data submission period, the record will automatically be flagged for publication in the next publication cycle.

For instructions on re-newing a record’s delay in publication status, refer to the Open Payments System Quick Reference Guide: Payment Category Page and Delay in Publication located on the Resources page of the Open Payments website.

“NEW” Do applicable manufacturers and applicable GPOs need to re-certify their Open Payments system registration each program year?

Yes. Each calendar year, reporting entities (applicable manufacturers or applicable GPOs) need to re-certify their profile information.

Specifically, reporting entities that registered in the Open Payments system in the prior calendar year are required to re-certify prior to taking any actions in the Open Payments system in the next calendar year. No submission or dispute resolution activities are available for a registered entity until that entity is re-certified. In addition, viewing previously submitted records will not be available until that entity is re-certified.

During re-certification, the user will confirm either that the identifying details in the entity’s Open Payments profile are accurate, or the user will update those details in the entity profile if any information is inaccurate. Note that only those who hold the user role of “officer” in the Open Payments system for that reporting entity can re-certify the entity. If there is no active officer for the reporting entity, contact the CMS Open Payments Help Desk at openpayments@cms.hhs.gov or 1-855-326-8366 for assistance with re-certification and nominating/approving a new officer. For additional guidance on how to re-certify, refer to the “Open Payments System Quick Reference Guide: Applicable Manufacturer and Applicable GPO Registration and Re-Certification” located on the Resources page of the Open Payments website.

“NEW” What happens if I do not re-new a record’s delay in publication status?

A request for a delay in publication must be re-newed each year. If this request is not re-newed each year, the record will automatically be flagged for publication in the next publication cycle. So, records delayed in publication for the 2013 program year that are not re-newed for delay in publication for the 2014 program year will automatically be published by June 30, 2015.

“NEW” How do I remove a delay in publication request for a previously submitted record?

A request for a delay in publication must be renewed each year. So, if the record was previously submitted in a prior year and the request is not renewed each year by the end of the data submission period, the record will automatically be flagged for publication in the next publication cycle. That means the user doesn’t have to do anything to remove the delay in publication request.

However, if the previously submitted record was submitted in the current reporting year, follow the instructions in the Open Payments System Quick Reference Guide: Payment Category Page and Delay in Publication located on the Resources page of the Open Payments website.