Open Payments/Sunshine Act


Open Payments/Sunshine Act Resources

The Open Payments system is a website created by CMS to publish data from pharmaceutical, biological, and medical device manufacturers (“Applicable Manufacturers”) about payments and other transfers of value to physicians, dentists, and teaching hospitals. 

Providers can search their data here:


CMS Updates Open Payments Data

On January 17, 2018, the Centers for Medicare & Medicaid Services (CMS) updated the Open Payments dataset to reflect changes to the data that took place since the last publication on June 30, 2017. The updated dataset is now available for viewing at

CMS updates the Open Payments data at least once annually to include updates from disputes and other data corrections made since the initial publication of the data.

The refreshed Open Payments Data Set includes:

  • Record Updates: Changes to non-disputed records that were made on or before November 15, 2017, are published.
  • Disputed Records: Dispute resolutions completed on or before December 31, 2017 are displayed with the updated information. Records with active disputes that remained unresolved as of December 31, 2017 are displayed as disputed.
  • Record Deletions: Records deleted before December 31, 2017 were removed from the Open Payments database. Records deleted after December 31, 2017, remained in the database but will be removed during the next data publication in June 2018.

The following is not included in the data refresh:

  • Any records submitted to the Open Payments system for the first time after the close of the Program Year 2016 submission window (March 31, 2017). 
  • Any records that were disputed and for which dispute resolution resulted in a change to the covered recipient.

Note: Updates not included in the refresh are due to the requirement that covered recipients must be provided an opportunity to review data attributed them for accuracy. For more information about the Open Payments Program timeline, visit

This financial data was submitted by applicable manufacturers and group purchasing organizations (GPOs).

Review and Correct Your Payment Data

Providers have the option to view and dispute payment data submitted by Applicable Manufacturers.  Even if you do not believe you received payments, you are advised to register and verify that your information is accurately represented in the Open Payments system. 

  • May 15, 2017 is the deadline to submit corrections to payment data that will be posted on Open Payments in June of 2017. Providers can submit disputes after May 15th, but information posted on the Open Payments website will not be updated until the next “resolution period,” as determined by CMS. 
  • The opportunity to dispute payment data expires at the end of the calendar year when the record is published (e.g., 2016 data published in June 2017 can be disputed through December 2017). 

Live Help Desk: Email questions to the Help Desk at [email protected] or call 1-855-326-8366, Monday through Friday, from 8:30 a.m. to 7:30 p.m. (ET).

  • Inactive accounts: If you previously registered but your account has been inactive for more than 60 days, you will need to login to the CMS Secure Portal, enter your user ID and correctly answer all challenge questions.  If your account has been inactive for more than 180 days, your EIDM account will be deactivated, and you should contact the Live Help Desk (see above).

New Registration

The two-step registration process includes a brief waiting period between completing registration and receiving access to your payment data. CMS states that the registration process takes approximately 30 minutes.

You will need the following information to register:

  • All active state license number(s) (SLN)
  • National Provider Identifier (NPI) number (if you have one)
  • Drug Enforcement Agency (DEA) number (if you have one)
  • If you do not enter an NPI number, you will likely have to enter a specialty code obtained from the Physician Taxonomy Codes.
  • If you are not a clinical provider, but receive payments from an Applicable Manufacturer (e.g., a non-physician Principal Investigator), contact the Help Desk for login assistance.

Note regarding delegation: It is unlikely that anyone else will be able to correctly answer the identity verification questions on your behalf.  Once you establish an account, you can designate one authorized representative.

Two registration steps are required:

1. Identity verification: This is done in the CMS Enterprise Identity Data Management (EIDM) system, at (select “New User Registration”).

    a. Refer to the EIDM Quick Reference Guide if needed:   

    b. Ensure the name entered for EIDM registration matches exactly with the way your name is listed in the National Plan and Provider Enumeration System (NPPES).
    c. You will be asked questions similar to what you would see on a credit report to verify your identity such as questions about what high school you graduated from, or who services your mortgage.
    d. You will receive an email confirming vetting success or failure. If unsuccessful, contact the Help Desk.

 2. Register in the Open Payments system

    a. Log in to the CMS Enterprise Portal at https://portal.cms.govusing your EIDM credentials, navigate to the Open Payments home page, and select “Create My Profile.”
    b. Most users will select “Physician” as the profile type.
    c. You will need additional professional information, such as your business email, phone, practice name, and address.
    d. The automatic vetting process normally takes less than 24 hours, though it could take longer depending upon the completeness of the information provided by the user and the number of physicians undergoing vetting at the same time.

Reviewing and Disputing Records

  • After reviewing your 2015 payment information, go to the “Review and Dispute” tab and enter your name.  You may take the following actions on a record:
    • Affirm the record (you are not required to take this step, as unaffirmed records will still be published; affirmed records can be subsequently disputed)
    • Initiate a dispute (reporting entity will receive an email notification of the dispute)
    • Withdraw a dispute
  • Dispute resolution takes place outside the Open Payments system; CMS does not mediate disputes between the provider and the Applicable Manufacturer.
    • New this year: Applicable manufacturers who report data are now required to provide contact information to facilitate the dispute resolution process.
    • Contact information can be found on the “Record Detail” page; select “Record ID”

CMS Open Payments User Guide

For complete information about the Open Payments system, including screen shots of the website and detailed user instructions, see (Part IV: Physicians and Teaching Hospitals, begins on page 223 of the PDF)



Page updated 06-26-2017