Elizaveta Bannova, Billing Department, WCH
The 45-day review period has started. Missing it won’t cost you money directly — but it may cost you your reputation.
Starting April 1 and running through May 15, 2026, the Centers for Medicare & Medicaid Services (CMS) opened the annual pre-publication review and dispute window for the Open Payments program. For physicians, nurse practitioners, physician assistants, certified nurse-midwives, CRNAs, clinical nurse specialists, and teaching hospitals, this 45-day window is the only formal opportunity to review — and if necessary, challenge — the financial data that drug and medical device companies have reported about them before it becomes publicly visible to patients, employers, and journalists in June 2026.
This is not a bureaucratic formality. The data that gets published will be searchable by anyone. It will sit in a national database for years. Getting it wrong — or letting someone else’s reporting error go uncorrected — has real professional consequences.
What Is Open Payments, and Why Does It Matter?
Open Payments was created under the Affordable Care Act as a transparency mechanism. Pharmaceutical companies, medical device manufacturers, and group purchasing organizations are required to report every financial transfer to covered recipients: speaking fees, consulting payments, meals, travel, research funding, royalties, ownership interests, and more. The program covers Program Year 2025 data submitted by reporting entities between February 1 and March 31, 2026, along with any corrections to prior years.
The practical implication: a single misattributed payment — a conference dinner billed to the wrong physician, a consulting contract matched to the wrong NPI — shows up in your public profile and cannot be corrected after publication without going through a much slower, post-publication dispute process. The pre-publication window is your chance to stop that before it happens.
The Three Actions Covered Recipients Should Take Right Now
1
Register — if you haven’t already
Participation in review and dispute requires registration in the Open Payments system at openpayments.system.cms.gov. Without an account, you cannot see your attributed data, let alone dispute it. Registration is free and open to all covered recipients. Step-by-step instructions are in the Open Payments User Guide for Covered Recipients.
2
Review every record — and affirm what is correct
This is a point many providers miss: simply logging in and viewing the data does not signal agreement. CMS requires an explicit affirmation for each record you agree with. Think of it as signing off on an expense report — silence is not approval. Review carefully: check the amounts, dates, nature of payment, and whether the payment was actually made to you and not a provider with a similar name or NPI.
3
Dispute inaccurate records before May 15
If you find a payment that is incorrect — wrong amount, wrong category, not yours at all — you must initiate a dispute through the system no later than May 15, 2026. Only disputes initiated by that date can be reflected in the June 2026 publication. Critically: CMS does not mediate the dispute. Once you flag it, you work directly with the reporting company to resolve it. Make sure your contact information in the system is current, so the company can reach you.
What Happens if You Do Nothing?
Participation is voluntary. CMS will not penalize you for skipping the review window. But the data will publish regardless — whether it is accurate or not. Once published in June 2026, any corrections go through a post-publication dispute process, which is slower and does not guarantee changes before the data is widely indexed and cited. Patients researching a physician on ProPublica’s Dollars for Docs tool or similar platforms will see whatever CMS publishes.
For providers in specialties under high public scrutiny — orthopedics, cardiology, oncology, pain management — this is especially consequential. A large speaking-fee payment attributed to the wrong physician, or a correctly attributed payment that appears in a misleading category, can prompt patient questions or even media coverage that is difficult to walk back.
A Practical Note for Group Practices and Hospitals
Compliance officers and practice administrators should treat the Open Payments review window the same way they treat year-end tax preparation: assign responsibility, set an internal deadline well before May 15, and confirm that all affiliated covered recipients are registered. For large groups with dozens of providers, a centralized review workflow — where someone flags records for individual providers to affirm or dispute — is far more reliable than expecting each clinician to log in independently under deadline pressure.
Key Dates & Contacts
| Review window opens | April 1, 2026 |
| Dispute deadline | May 15, 2026 |
| Data publication | June 2026 |
| Help Desk email | openpayments@cms.hhs.gov |
| Help Desk phone | 1-855-326-8366 |
| Hours | Mon–Fri, 9 am–5 pm ET |
Source: CMS Open Payments Program, April 2026 pre-publication notice. For full guidance, visit the Covered Recipients Review and Dispute page on the CMS Open Payments website.
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