CMS Open Payments Reporting System Update: Plan for Potential Processing Delays

As many Life Sciences organizations move into the busy season of U.S. Federal Open Payments (Sunshine Act) reporting ahead of the March 31st submission deadline, operational details matter more than ever.

During a recent submission to Centers for Medicare & Medicaid Services (CMS), several records MedPro attempted to submit on behalf of a customer remained in “System Processing” status for an extended period—often exceeding two hours. After contacting CMS directly, we identified an important update regarding the current Open Payments submission environment leading to potential delays:

What’s Happening

  • CMS is working with a new vendor for record matching this year.
  • If a record is submitted without a National Provider Identifier (NPI), it may remain in System Processing significantly longer than expected.
  • In many cases, these records will eventually process, typically within a ~4 hour window, but we have seen instances of this taking much longer.
  • If records don’t clear, the missing NPI must be identified and corrected for processing to complete.

Why This Matters for Reporting Life Sciences Manufacturers

With the March31st submission deadline approaching, even the most prepared teams may find their submission process delayed or falling behind schedule with external lag. Especially at this stage in the reporting cycle, any added delay creates a significant risk of missing the deadline.

These extended System Processing windows can jeopardize your submission by:

  • Disrupting submission planning
  • Creating uncertainty around file acceptance
  • Compressing review and correction timelines

Practical Considerations for Reporting Teams

To navigate the external processing delays and protect your team’s submission timeline, we recommend implementing the following strategies:

To navigate the external processing delays and protect your team’s submission timeline, we recommend implementing the following strategies:

Front-Load NPI Validation

Validate NPIs prior to submission, whenever possible. Pre-clearing your data ensures you bypass the secondary matching window that is currently triggering the most significant delays for records without a National Provider Identifier.

Build a “Buffer” Window

We suggest shifting your internal submission target date 24–48 hours earlier than planned. This creates the necessary lead time to absorb any unplanned external lags.

Proactively Monitor Status

Actively monitor file statuses in the portal rather than assuming immediate movement. If a record remains in “System Processing” for an extended period, it should be flagged for review. Work with you vendor, internal teams, and CMS to update data or at least create awareness.

Reliable Open Payments reporting depends on disciplined processes, proactive engagement and managing time intentionally.

At MedPro, we prioritize these operational details to help our customers anticipate and identify friction points early – including identification and supplementation of NPIs – to drive informed commercial and compliance operations.

Let’s Compare Notes

If your team is seeing similar processing behavior or if you are refining your March submission strategy, we welcome the conversation.

Our goal is simple: ensure reporting is accurate, timely, and low-risk for the organizations we support.

If this insight is helpful, feel free to connect or reach out directly.

Not a MedPro Compliance Reporting ID (MCR) Customer?

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