On Friday, February 7, 2014, the Centers for Medicare and Medicaid Services (CMS) announced that Open Payments registration is scheduled to begin on Tuesday, February 18, 2014 for applicable manufacturers and applicable group purchasing organizations (“GPOs”). CMS released its announcement via email to the Open Payments email distribution list. According to CMS, the Open Payments program is designed to create greater public transparency about financial transactions among doctors, teaching hospitals, drug and device manufacturers, and other healthcare businesses. The agency provided new details about its plans for a two-phased approach to the registration and data submission processes for the first reporting period.

This announcement is tantamount to a delay of the requirement for full data submissions covering the first reporting period until May 30, 2014, at the earliest (and possibly later), although certain interim information (e.g., certain aggregate information about data covering the first reporting period) and registrations must still be provided by March 31, 2014...