CMS Open Payments Review & Dispute Period: Practical Tips for Manufacturers

Each year, the CMS Open Payments pre‑publication review and dispute period runs from April 1 through May 15. During this window, physicians and teaching hospitals have the opportunity to review submitted data and initiate disputes to ensure accuracy ahead of public release on June 30.

For manufacturers, this period is more than a technical checkpoint. While disputes often focus on individual records, the way organizations manage this process can have broader implications for their compliance posture, data integrity, and relationships with healthcare professionals (HCPs) and healthcare organizations (HCOs).

Receiving a dispute should not be viewed solely as a corrective exercise—it is also an opportunity to reinforce internal controls, validate data integrity, and strengthen engagement with healthcare professionals (HCPs) and healthcare organizations (HCOs). Organizations that approach disputes in a timely, thoughtful, and well-documented manner can mitigate compliance risk while building credibility with covered recipients.

Below are several key considerations when managing and resolving Open Payments disputes:

1. A dispute does not necessarily indicate an error
Disputes may arise for a variety of reasons, including timing discrepancies, misunderstandings regarding the nature of services provided, or administrative inconsistencies.

Each dispute should be evaluated objectively, with a thorough review of supporting documentation before any determination is made. Treating every dispute as a confirmed error can introduce unnecessary rework and risk.

2. Documentation is foundational
The Centers for Medicare & Medicaid Services expects manufacturers to maintain sufficient documentation to support reported data and dispute resolution decisions. At a minimum, companies should ensure they have ready access to:

• • Executed contracts and agreements
  • Payment support (e.g., invoices, receipts)
  • Correspondence with the covered recipient
  • Internal records describing the services provided

Well-organized documentation enables efficient resolution and supports defensibility in the event of audit or inquiry.

3. Implement a clear communication strategy
Where appropriate, engage directly with the covered recipient to clarify the nature of the reported transaction. Transparent, professional communication can resolve misunderstandings quickly and reduce the likelihood of recurring disputes in future reporting cycles.

A consistent communication strategy also reinforces trust and professionalism with HCPs and HCOs.

4. Understand the impact on public reporting
Disputed records remain flagged within the Open Payments system until resolved. While disputes do not delay publication, they are visible in the public dataset and may carry reputational implications. Active tracking and timely resolution are critical to ensuring the accuracy and completeness of final published data.

For this reason, active tracking and timely resolution of disputes are critical to ensuring the accuracy and completeness of the final publicly reported data.