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.

Frequently Asked Questions

Missing the March 31 deadline can compress your review and correction window and put your overall submission timeline at risk. As the deadline approaches, delays in system processing or incomplete provider data can prevent records from moving forward. Strong provider data validation, including healthcare license verification, is one of the most effective ways to reduce last-minute submission risk.

CMS uses NPIs to match submitted records to the correct provider. Without a valid identifier, records may remain in “System Processing” while additional matching attempts occur, slowing acceptance of the full disclosure file. Confirming provider identifiers through healthcare license verification before submission helps avoid this bottleneck.

The right partner does more than format and submit a disclosure file. For Open Payments reporting, two capabilities matter most. The first is provider data quality: a partner with access to a comprehensive, continuously maintained HCP and HCO database reduces the risk of missing or unmatched identifiers before they stall records in CMS processing. The second is an end-to-end platform that handles data ingestion, mapping and reportability alongside submission, rather than relying on a clean feed from the manufacturer as a starting point.

Organizations working with MCR benefit from both, built on MedProID’s 33 million HCP and HCO records and designed to manage the full reporting workflow from source data to final submission.

See how MCR supports Open Payments reporting.

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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