Dispute and Correction

When a reporting entity submits records showing payments made to a covered recipient, the covered recipient can review the information during the 45-day pre-publication review and dispute period before it become public. If the covered recipient believes the records contain discrepancies, they can initiate a dispute with the reporting entity. This gives the reporting entity an opportunity to correct the information before the data is published.

When a dispute is initiated, an email notification will be sent to the person designated by the reporting entity as the submitter. A dispute can lead to one of three outcomes:

1. Resolved - The reporting entity and covered recipient worked together and reached a resolution. Once this step is completed, the review and dispute status will automatically be updated to “resolved” in Open Payments.
   When a dispute is resolved by updating the record(s), the reporting entity must resubmit and re-attest the data.
2. Resolve No Change - The reporting entity and the covered recipient worked together in accordance with the guidance in the Final Rule and determined the originally reported information is correct and no change is necessary.
3. Withdrawn - The covered recipient withdrew the dispute and no further action is needed.

Reporting entities can resolve disputes during the pre-publication review and dispute period and have an additional 15 days (May 16 – May 30) to resolve and submit corrections on outstanding disputes. Disputed data that is not resolved by the end of the additional 15-day period will be published on the public website as disputed.

Although the pre-publication review period is from April 1-May 15, covered recipients can initiate disputes through the end of the calendar year (December 31) on any newly submitted data. Additionally, covered recipients can initiate disputes outside the Open Payments system after the December 31 deadline for the calendar year. It’s important for reporting entities to know this and be prepared to work with the covered recipient to resolve disputes if needed.

The Centers for Medicare & Medicaid Services (CMS) does not facilitate or mediate disputes. It is up to the reporting entity and covered recipient to work directly with each other to resolve any disputes.

For more information on review and dispute timing and publication refer to the Review and Dispute Timing and Data Publication Quick Reference Guide (PDF).