Top Mistakes to Avoid When Submitting CMS Open Payments Data
Table of content
- Mistake #1: Using the Wrong File Template
- Mistake #2: Exceeding the File Size Limit
- Mistake #3: Mixing Payment Types or Record Purposes in a Single File
- Mistake #4: Submitting Records with Unresolved Validation or Matching Errors
- Mistake #5: Confusing Upload with Official Submission
- Mistake #6: Missing the Attestation Deadline
- The Bottom Line
- Take the Complexity Out of Open Payments Reporting
Author
May Khan leads the Compliance Services team at Vector Health, a SaaS company focused on life sciences compliance. Her experience includes global transparency reporting, Sunshine Act strategy, and HCP risk monitoring. At Vector, she coordinates cross-functional teams focused on data integrity, customer service, and regulatory alignment.
Vector Health Compliance
Your Leading Partner in Global Sunshine Compliance
For compliance teams at life sciences companies, the CMS Open Payments submission window is one of the most high-stakes periods of the year. The process involves multiple steps, technical requirements, and a hard deadline — and even small missteps can trigger errors that delay submission, require extensive rework, or worse, result in a late attestation and potential civil monetary penalties.
The good news is that most submission errors are preventable. Based on the CMS Open Payments data submission requirements for Program Year 2025, here are the most common mistakes to watch out for — and how to avoid them.
Mistake #1: Using the Wrong File Template
Bulk file submissions must be prepared using the correct template for the specific program year and payment type being reported. Submitting a file built on the wrong template — or one where the selected payment category at upload does not match the template used to prepare the file — will cause an immediate file validation failure. The system will reject the entire file, meaning none of the records within it will be processed.
How to avoid it: Always download templates directly from the Open Payments Resources page or from within the system itself, and double-check that the payment category selected during upload matches the template used to build your file.
Mistake #2: Exceeding the File Size Limit
Both CSV and ZIP file uploads are capped at 250 MB. Files that exceed this threshold will fail immediately at the file validation stage, before any records are even reviewed. This is a surprisingly easy trap to fall into for organizations reporting a high volume of transactions in a single file.
How to avoid it: Split large datasets across multiple files. There is no limit on the number of files that can be uploaded into the system, so breaking a large submission into smaller files is both permissible and advisable.
Mistake #3: Mixing Payment Types or Record Purposes in a Single File
Each bulk file may contain records for only one payment category — general payments, research payments, or ownership and investment interests. Similarly, all records within a file must share the same Resubmission File Indicator, meaning a single file cannot combine new records with deletions, resubmissions, or publication delay updates.
How to avoid it: Organize your data into separate files by payment type and by record purpose before uploading. Treat each file as a single-purpose submission.
Mistake #4: Submitting Records with Unresolved Validation or Matching Errors
The Open Payments system will not allow final submission or attestation to proceed if any records contain unresolved errors. Record validation errors — such as invalid characters, blank required fields, incorrect field lengths, or values that do not align with CMS-approved datasets — must all be corrected first. Matching errors, which occur when covered recipient information cannot be verified against CMS reference data, are equally blocking.
How to avoid it: Build error review into your submission timeline. After uploading, actively monitor email notifications and error logs, and prioritize resolving both validation and matching errors well before the reporting deadline. The Submission Data Mapping Document on the Open Payments Resources page is an essential reference for understanding formatting requirements.
Mistake #5: Confusing Upload with Official Submission
One of the most consequential misunderstandings in the Open Payments process is assuming that uploading data to the system is the same as reporting it. It is not. Data uploaded to Open Payments is not considered officially reported until it has gone through final submission and been attested to by an authorized attester within the organization.
How to avoid it: Ensure your internal workflow accounts for all stages — upload, error resolution, final submission, and attestation — and assign clear ownership for each step. Remember that final submission processing time can vary, so plan accordingly and do not wait until the last day.
Mistake #6: Missing the Attestation Deadline
Attestation is the legally binding step that certifies submitted data is accurate, complete, and timely. Only users designated with the Attester role within the system can complete this step — and it must cover all records for the program year across all payment categories at once. Submissions that are not attested by the published reporting deadline, which is March 31st, are considered late and may be subject to civil monetary penalties.
How to avoid it: Mark the attestation deadline prominently in your compliance calendar, confirm early that your designated attester has system access, and use the “Notify Attester” button to alert them as soon as records are ready. Also keep in mind that any changes to previously attested data will require re-attestation — so avoid last-minute edits wherever possible.
The Bottom Line
CMS Open Payments reporting is a process with little margin for error. File formatting issues, unresolved validation problems, and missed attestation deadlines are all avoidable — but only if your team has the right processes, tools, and awareness in place ahead of the submission window. Reviewing these common pitfalls before you begin is one of the simplest ways to protect your organization from unnecessary delays and compliance risk.
Take the Complexity Out of Open Payments Reporting
Vector Health Compliance’s US Transparency Reporting solution is designed to help compliance teams eliminate the manual heavy lifting behind federal transparency reporting. From data validation and error management to coordinating final submission and attestation, the platform gives your team a more efficient, reliable path through the Open Payments process, year after year.
Learn more about our solution and reach out to us here.
Disclaimer: This blog post is based on the CMS Open Payments data submission process documentation published by CMS in January 2026. For the most current guidance, always refer to the official Open Payments User Guide for Reporting Entities and the CMS Open Payments website.
Table of content
- Mistake #1: Using the Wrong File Template
- Mistake #2: Exceeding the File Size Limit
- Mistake #3: Mixing Payment Types or Record Purposes in a Single File
- Mistake #4: Submitting Records with Unresolved Validation or Matching Errors
- Mistake #5: Confusing Upload with Official Submission
- Mistake #6: Missing the Attestation Deadline
- The Bottom Line
- Take the Complexity Out of Open Payments Reporting
For compliance teams at life sciences companies, the CMS Open Payments submission window is one of the most high-stakes periods of the year. The process involves multiple steps, technical requirements, and a hard deadline — and even small missteps can trigger errors that delay submission, require extensive rework, or worse, result in a late attestation and potential civil monetary penalties.
The good news is that most submission errors are preventable. Based on the CMS Open Payments data submission requirements for Program Year 2025, here are the most common mistakes to watch out for — and how to avoid them.
Mistake #1: Using the Wrong File Template
Bulk file submissions must be prepared using the correct template for the specific program year and payment type being reported. Submitting a file built on the wrong template — or one where the selected payment category at upload does not match the template used to prepare the file — will cause an immediate file validation failure. The system will reject the entire file, meaning none of the records within it will be processed.
How to avoid it: Always download templates directly from the Open Payments Resources page or from within the system itself, and double-check that the payment category selected during upload matches the template used to build your file.
Mistake #2: Exceeding the File Size Limit
Both CSV and ZIP file uploads are capped at 250 MB. Files that exceed this threshold will fail immediately at the file validation stage, before any records are even reviewed. This is a surprisingly easy trap to fall into for organizations reporting a high volume of transactions in a single file.
How to avoid it: Split large datasets across multiple files. There is no limit on the number of files that can be uploaded into the system, so breaking a large submission into smaller files is both permissible and advisable.
Mistake #3: Mixing Payment Types or Record Purposes in a Single File
Each bulk file may contain records for only one payment category — general payments, research payments, or ownership and investment interests. Similarly, all records within a file must share the same Resubmission File Indicator, meaning a single file cannot combine new records with deletions, resubmissions, or publication delay updates.
How to avoid it: Organize your data into separate files by payment type and by record purpose before uploading. Treat each file as a single-purpose submission.
Mistake #4: Submitting Records with Unresolved Validation or Matching Errors
The Open Payments system will not allow final submission or attestation to proceed if any records contain unresolved errors. Record validation errors — such as invalid characters, blank required fields, incorrect field lengths, or values that do not align with CMS-approved datasets — must all be corrected first. Matching errors, which occur when covered recipient information cannot be verified against CMS reference data, are equally blocking.
How to avoid it: Build error review into your submission timeline. After uploading, actively monitor email notifications and error logs, and prioritize resolving both validation and matching errors well before the reporting deadline. The Submission Data Mapping Document on the Open Payments Resources page is an essential reference for understanding formatting requirements.
Mistake #5: Confusing Upload with Official Submission
One of the most consequential misunderstandings in the Open Payments process is assuming that uploading data to the system is the same as reporting it. It is not. Data uploaded to Open Payments is not considered officially reported until it has gone through final submission and been attested to by an authorized attester within the organization.
How to avoid it: Ensure your internal workflow accounts for all stages — upload, error resolution, final submission, and attestation — and assign clear ownership for each step. Remember that final submission processing time can vary, so plan accordingly and do not wait until the last day.
Mistake #6: Missing the Attestation Deadline
Attestation is the legally binding step that certifies submitted data is accurate, complete, and timely. Only users designated with the Attester role within the system can complete this step — and it must cover all records for the program year across all payment categories at once. Submissions that are not attested by the published reporting deadline, which is March 31st, are considered late and may be subject to civil monetary penalties.
How to avoid it: Mark the attestation deadline prominently in your compliance calendar, confirm early that your designated attester has system access, and use the “Notify Attester” button to alert them as soon as records are ready. Also keep in mind that any changes to previously attested data will require re-attestation — so avoid last-minute edits wherever possible.
The Bottom Line
CMS Open Payments reporting is a process with little margin for error. File formatting issues, unresolved validation problems, and missed attestation deadlines are all avoidable — but only if your team has the right processes, tools, and awareness in place ahead of the submission window. Reviewing these common pitfalls before you begin is one of the simplest ways to protect your organization from unnecessary delays and compliance risk.
Take the Complexity Out of Open Payments Reporting
Vector Health Compliance’s US Transparency Reporting solution is designed to help compliance teams eliminate the manual heavy lifting behind federal transparency reporting. From data validation and error management to coordinating final submission and attestation, the platform gives your team a more efficient, reliable path through the Open Payments process, year after year.
Learn more about our solution and reach out to us here.
Disclaimer: This blog post is based on the CMS Open Payments data submission process documentation published by CMS in January 2026. For the most current guidance, always refer to the official Open Payments User Guide for Reporting Entities and the CMS Open Payments website.
Author
May Khan leads the Compliance Services team at Vector Health, a SaaS company focused on life sciences compliance. Her experience includes global transparency reporting, Sunshine Act strategy, and HCP risk monitoring. At Vector, she coordinates cross-functional teams focused on data integrity, customer service, and regulatory alignment.
Vector Health Compliance
Your Leading Partner in Global Sunshine Compliance