CMS Open Payments Reporting Guide: Data Submission Process Explained

According to the data submission process outlined by CMS, reporting entities participating in the Open Payments program face a structured set of requirements for disclosing financial transactions with covered recipients. Whether you are a first-time submitter or a seasoned compliance professional, understanding the end-to-end submission workflow is essential to meeting federal reporting obligations accurately and on time.

This guide breaks down the key components of the CMS Open Payments data submission process for Calendar Year 2026, covering Program Year 2025 data, submission methods, error management, and the attestation requirements that finalize your reporting.

What Must Be Reported and When

During the Calendar Year 2026 data submission window, reporting entities are required to disclose payments, transfers of value, and ownership or investment interests pertaining to Program Year 2025, that is, transactions occurring between January 1 and December 31, 2025. In addition to current-year data, submitters may also report any eligible payments from prior program years that were previously omitted, and they are permitted to revise records submitted in earlier cycles.

There are important limitations to keep in mind, however. Archived Program Years 2013 through 2018 are off-limits for both new submissions and edits, as are any program years that have been officially closed. Attempting to submit or modify data for these periods is not permitted within the system.

Two Paths to Submission: Bulk Upload vs. Manual Data Entry

The Open Payments system accommodates two distinct methods for entering data, and reporting entities may use either one or a combination of both, depending on their needs.

Bulk File Upload

Organizations managing large data volumes will generally find bulk file upload to be the more efficient route. The system accepts two file formats for this method:

• CSV files — specifically, pipe-delimited (|) character-separated value files. Templates for each program year and payment type are available on the Open Payments Resources page and within the system itself. Submitters must use the correct template corresponding to their target program year.
• ZIP files — compressed archives that must contain only pipe-delimited CSV files.

A few critical rules govern bulk file uploads. Each file may contain records for only one payment category: general payments, research payments, or ownership and investment interests. No single file may exceed 250 MB, though there is no ceiling on the total number of files that can be uploaded. Beyond adding new records, bulk uploads can also be used to delete existing entries, resubmit previously reported records, or update the publication delay status of a record, all communicated through the Resubmission File Indicator field. Importantly, all records within a single bulk file must share the same Resubmission File Indicator value.

Manual Data Entry via GUI

For entities with lower submission volumes, CMS recommends manual data entry through the system’s Graphical User Interface (GUI). This approach is more accessible for organizations that lack the technical infrastructure or data-handling expertise required to prepare properly formatted CSV files.

Manual entry can be used alongside bulk uploads, and the GUI includes a helpful feature that allows submitters to copy or duplicate payment details across multiple program years, reducing repetitive data entry for recurring transactions.

Additionally, reporting entities have the option to delegate the submitter role to a third-party company within the Open Payments system, allowing an external organization to submit data on their behalf.

The Five-Step Submission Process

Once data is ready, the submission workflow proceeds through five sequential stages:

Step 1: Log In

The submitter accesses the Open Payments system using their authorized credentials.

Step 2: Upload Data

Data is entered either through bulk file upload (CSV or ZIP, max 250 MB per file, using the correct template) or manual entry through the GUI.

Step 3: Data Validation and Matching

After upload, the system automatically runs validation and matching checks. For bulk uploads, outcomes are communicated via email. For manual entries, validation results appear in real time on the interface, while matching results are displayed on the Record ID pages.

Step 4: Final Submission

Once the records you intend to submit are in ‘Ready for Submission’ status and there are no records in ‘System Processing’, the submitter can initiate Final Submission. The submitter can then use the “Notify Attester” button to alert the designated attester that records are prepared for attestation. 

Step 5: Attestation

The attester receives an email notification when records reach “Ready for Attestation” status. Attestation covers all submitted records for the program year across all three payment categories simultaneously.

Error and Warning Notifications

Submitters are kept informed throughout the process via onscreen messages and email notifications. For bulk file submissions, file validation errors are communicated directly in the notification email, while record-level and matching errors are captured in a downloadable error log. For manual entry, record validation issues appear as real-time onscreen messages during data entry, and matching problems can be found on the record Overview page or by filtering for records with a “Failed Matching” status.

All error and warning logs reference specific codes that identify the underlying cause of each issue. These codes are explained in the “Error and Warning Code Key,” which is available on the Open Payments Resources page. Drug and medical device data is validated against CMS-approved datasets provided annually by the U.S. Food and Drug Administration (FDA), so submitters encountering related errors should consult the corresponding reference files and instruction documents.

Warning notifications, rather than outright errors, may be triggered in certain scenarios, such as when physician or non-physician practitioner licenses were valid at some point after August 1, 2013, or January 1, 2021, respectively, but had expired for the entirety of the relevant program year. Records flagged with warnings are marked with a warning icon in the system, and submitters should carefully review the associated license information. If the data is correct, no changes are required, and the record can advance through the process. If the data is incorrect, the record should be corrected or deleted.

Final Submission and Attestation: Making It Official

Uploading data to the Open Payments system is not the same as reporting it. All records must undergo final submission and attestation to be considered officially reported. Final submission processes all records in a given payment category and program year simultaneously, regardless of how those records were submitted. Given the scope of this step, it may take several hours to complete; submitters receive an automated email confirmation once it is successfully processed.

Attestation is the legally binding step that certifies the submitted information is accurate, complete, and timely. Only users holding the Attester role within the system may perform this action. Attestation must cover all records for a given program year; it cannot be done selectively by record, file, or payment type. If any previously attested data is subsequently modified, deleted, or otherwise changed, re-attestation is required.

Entities that have no payments to report may attest to that fact directly through the “Manage Entities” tab in the Open Payments system.

Timeliness matters: attestation must be completed by the established reporting deadline for the program year. Submissions that are not attested by the deadline are considered late and may be subject to civil monetary penalties.

The Assumptions Statement: Providing Context for Your Data

During the attestation process, attesters have the option to include an assumptions statement. This free-form narrative field documents the reasonable assumptions made and methodologies applied when reporting payments or other transfers of value. This can be a valuable tool for providing transparency and context around complex reporting decisions.

The assumptions statement accommodates up to 8,000 characters (including spaces) and can be edited after initial submission if needed. For more detailed guidance, refer to Section 4.15 of the Open Payments User Guide for Reporting Entities.

Key Takeaways for a Smooth Submission

• Know your submission method: Bulk upload suits high-volume reporters with data expertise; GUI manual entry is recommended for smaller filers.
• Use the right template: Bulk CSV files must match the correct program year and payment type template to avoid file validation failures.
• Resolve all errors before final submission: The system will not allow final submission or attestation until every error on every record has been corrected.
• Monitor your notifications: Email and onscreen alerts will guide you through the stages of upload, validation, and matching.
• Attest on time: Late attestation carries the risk of civil monetary penalties.

Consult the User Guide: Chapter 4 of the Open Payments User Guide for Reporting Entities is the definitive resource for detailed guidance on every aspect of the submission process.

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Learn more about the CMS Open Payments reporting process in our detailed guide.