On October 30, 2014, the Centers for Medicare and Medicaid Services (“CMS”) announced the procedure for applicable manufacturers and group purchasing organizations (“GPOs”) to report payment and ownership information that was previously excluded from reporting in the Open Payments system due to data errors.  Applicable manufacturers and GPOs will have until the end of the 2014 data submission and attestation period (expected to be March 31, 2015) to submit the corrected reports for the 2013 reporting year. 

Applicable manufacturers and GPOs were initially required to report payments made to physicians and teaching hospitals and ownership interests held by physicians for the period running from August 1, 2013, to December 31, 2013, by June 30, 2014.  As previously reported, after the initial reporting of 2013 data, CMS temporarily shut down the Open Payments system to address problems with data submissions.  After the shutdown, approximately one-third of the submitted records were flagged as having errors related to the identity of the recipient of the payment.  These payments were not included in the data that was publicly released on September 30, 2014. 

Applicable manufacturers and GPOs can now download a Removed Records Report from the Open Payments system showing the records that were removed.  A guide for correcting records is also available.  CMS will host a webinar on November 13, 2014 at 1:00pm EST to address the re-submission of data.