Transparency Reporting Solution
Manually validating large datasets is slow, labor-intensive, and can't keep up with deadlines, making anomaly detection and reporting overly complex.
Transparency Reporting Solution minimizes manual effort by automating data cleansing, validation, standardization, and organization, ensuring cleaner, compliant, and submission-ready spend reports.
With AI-trained models, compliance teams gain more time, less friction, and greater confidence in the accuracy and integrity of their federal and state level reports.
Core Capabilities
Comprehensive Visibility
Aggregate and monitor HCP/HCO spend across federal and state mandates for full transparency.
Regulatory Confidence
Automated data validation and CMS/state rule checks minimize errors and ensure report readiness.
Accurate, Standardized Reporting
Clean, match, and profile data across sources to meet complex reporting requirements with consistency.
Time-Saving Automation
Streamlined workflows for monthly/quarterly uploads, report preparation, and recipient validation reduce manual effort.
End-to-End Support
From data prep to dispute period assistance, the solution supports the full reporting cycle.
Deadline-Driven Compliance
Built-in scheduling and deadline tracking help teams meet CMS and state submission timelines with confidence.
Transparency Reporting Process Flow
Identify Data Sources
Aggregate spend data from all relevant systems and platforms into a single, unified pipeline for reporting.
- Concur (T&E Systems)
- ERP Systems
- CRO / R&D Platforms
- Medical Affairs Data
- Third-Party HCP Spend
Data Mapping & Business Rules
Establish the foundational logic that governs how data is interpreted and processed throughout the reporting cycle.
- Map data fields from source systems
- Define business rules and assumptions
Data Retrieval & Validation
Automate scheduled data ingestion and apply rigorous validation checks to ensure data integrity before processing.
- Scheduled data pulls (Monthly / Quarterly)
- Validate completeness and accuracy
- Entity validation for HCP / NPP / HCO
Data Processing
Apply AI-trained models to classify, analyze, and clean spend data, surfacing potential issues before submission.
- Determine reportable vs. non-reportable spend
- Classify spend by category
- Analyze for outliers, misclassification, and duplicates
Report Generation & Submission
Generate fully compliant, submission-ready reports for both CMS and state-level requirements.
- Generate CMS Open Payments reports
- Generate state-specific reports
- Submit final reports through designated portals
Post Submission Activities
Support compliance teams through the full post-submission lifecycle, from error resolution to analytical reporting.
- CMS error resolution
- Dispute resolution support
- Generate analytical reports
Compliance Reference
US Transparency & State Reporting Requirements
US Federal Reporting
Open Payments — CMS Section 6002
Applicable Pharmaceutical, Medical device manufacturers, and Group Purchase Organizations (GPO).
- Physicians
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Certified nurse midwives
All payments, gifts and other transfers of value made to U.S. physicians and teaching hospitals including:
- Consulting Fees
- Compensation for services other than consulting
- Honoraria
- Gift, Entertainment, Food and Beverage
- Travel and Lodging
- Research & Charitable Contributions
- Royalty or License Fees
- Current or Prospective Ownership
- Compensation for serving as faculty or speaker
- Grant, Space Rental or Facility Fee
- Debt Forgiveness, Long-term Medical Supply Loan, Acquisitions
Annual reports must be submitted to the Centers for Medicare and Medicaid Services through the online portal at portal.cms.gov
Nevada
Pharmaceutical Sales Representative Reporting
- Healthcare providers (HCPs) licensed, certified or registered in Nevada
- Pharmacies and employees thereof
- Operators and employees of medical facilities
- Persons licensed or certified under provisions of title 57 of NRS
A list of HCPs who have been provided by a pharmaceutical sales representative:
- Any compensation exceeding $10, or total compensation exceeding $100 in aggregate
- Name and manufacturer of each prescription drug for which a free sample was provided
- Name of each person who was given a free sample
Data points to be disclosed: Manufacturer name, Representative State ID, Transaction Date, Recipient Name, Professional Designation, NPI, Zip Code, Compensation Amount & Type; and if a sample drug was provided: Drug Name, NDC.
Submit the template file as an attachment via email to: drugdatabase@dhhs.nv.gov
Minnesota
Pharmaceutical Manufacturer Reporting
- Advanced practice registered nurses (APRNs)
- Physician assistants (PAs)
- Veterinarians
- Dental therapists
Payments, reimbursement or other compensation paid to HCPs registered and practicing in Minnesota during the calendar year in which the transfer of value is $100 or more to a particular covered recipient.
Data points: Name of practitioner, Professional designation, Address, Value of payment, Specific reason for payment.
- Professional samples provided to prescribers for free distribution to patients
- Transfers of value with combined retail value of $50 or less in a calendar year
- Payment to sponsor of a medical conference used solely for bona fide educational purposes
- Honoraria or payments less than $100 annually for faculty at professional conferences
- Compensation for consulting services less than $100 annually
Reports must be filed electronically. Complete the spreadsheet available on the Minnesota Board of Pharmacy website and return it attached to an e-mail at pharmacy.board@state.mn.us or on a CD-ROM.
District of Columbia
Pharmaceutical Manufacturers and Labelers
- All licensed HCPs including nurses, CDEs, registered dieticians, radiology technicians
- Non-teaching hospitals/clinics, Universities, Patient advocacy associations
- All licensed healthcare facilities (hospice, long-term care, dialysis, etc.)
- All expenses associated with advertising, marketing and direct promotion of prescription drugs through radio, television, magazines, newspapers, direct mail and telephone communications to D.C. residents
- Any expenditure for consulting and honoraria fees, charitable grants, educational programs, gifts, meals or entertainment over $25 in value, and travel reimbursement for District healthcare professionals
- Aggregate cost of employees or contractors who directly or indirectly engage in reportable activity
- Expenses of $25 or less
- Compensation and reimbursement for expenses in connection with a bona fide clinical trial of a new vaccine, therapy, or treatment that is of modest value
- Scholarships for recipients attending significant educational, scientific, or policy-making conferences
Submit the Excel workbook containing "Company Information," "Gift Expenses," and "Advertising Expenses" worksheets via email to doh.accessrx@dc.gov. Mail signed Company Information worksheet and a $5,000 check payable to "D.C. Treasurer" to: Department of Health, Pharmaceutical Control – AccessRx, 899 N. Capitol Street, NE, Second Floor, Washington, D.C. 20002.
Oregon
Pharmaceutical Company Representative Reporting
An individual authorized, certified, and licensed under the laws of Oregon to prescribe, dispense or provide pharmaceutical products to patients for treatment, diagnosis, injury, congenital or disease prevention.
Interactions healthcare professionals have with pharmaceutical representatives including video conference, email, telephonic conversation, in-person meetings, or leaving material/drug samples.
- HCP's License Type, Name, Address, NPI or Oregon State License Number
- Representative's License Number and Name
- Date, location, and duration of interaction
- Drug names promoted, monetary value of samples
- Gifts given and description of compensation
No exemptions.
A disclosure log must be submitted via the iReg Portal before April 1st. The reporting spreadsheet is available on the Oregon DFR website.
Massachusetts
Pharmaceutical and Medical Device Manufacturers
- Doctor, Dentist, Pharmacist
- Nurse practitioner
- Audiologist, Podiatrist
- Physical therapist
- Product education and training
- Modest meals in conjunction with product education and training
- Honoraria, consultant, speaker fees and related out-of-pocket expenses
- Reasonable travel and lodging necessary for training
- Demonstration or evaluation units
- Educational gifts (journal articles, anatomical models, textbooks)
- Charitable donations
Manufacturers must register with the Department of Public Health and pay a yearly fee of $2,000. Email the CSV file attachment with subject line "[Year] Disclosure Report" to dph.pharmaceutical.disclosure@state.ma.us
Connecticut
Pharmaceutical Manufacturers
Any pharmaceutical manufacturer that employs individuals to perform the duties of pharmaceutical sales representatives in the U.S.
- Independently practicing advanced practice registered nurses (APRNs) — Connecticut provides a list of applicable APRNs
Payment or other transfer of value, except when the transfer is made indirectly to an APRN via a third party and the applicable manufacturer is unaware of the APRN's identity or meets the exclusion criteria set by CMS Open Payments.
Data points to be disclosed:
- Manufacturer name
- Contact person name
- Contact person email
- Contact person's phone number
- Total value of payment to APRN
Email report to DCP.DrugManufacturers@ct.gov with the subject line "APRN Payment Report." An auto-response will be sent to the submitter's email address as proof of submission.
Any pharmaceutical manufacturer that employs individuals to perform the duties of pharmaceutical sales representatives in the U.S.
- All prescribing practitioners and pharmacists with whom Connecticut sales representatives interact
- Contact made with or a sample provided to a prescribing practitioner, a pharmacist, or an office staff member by a CT sales representative shall be reported
Data points to be disclosed:
- Name of Firm
- Name of Individual Sales Representative
- No. of Contacts
- CMS Classification / Specialty
- Gift value ($)
- 11 Digit NDC Code
- Drug Name
- Drug Strength
- WAC Price / List Price ($)
- Total Number of Samples in the Package
- Number of Samples Gifted
- Gifted Value ($)
- Only report those interactions that were done in the previous reporting year
- Manufacturers do not have to report indirect spend to a third party where the manufacturer is unaware of the recipient's identity
Email report to DCP.DrugManufacturers@ct.gov with the subject line "CT Sales Rep Report." An auto-response will be sent to the submitter's email address as proof of submission.
Vermont
Pharmaceutical and Medical Device Manufacturers
- Healthcare professionals
- Academic institutions
- Non-profit hospital foundations
- Educational and patient organizations located in or providing services in Vermont
- Members of the Green Mountain Care Board
- Samples (separate disclosure template)
- Device loaners (allowed for up to 120 days)
- Clinical and research payments
- Compensation for bona fide services
- Sponsorship and fellowship payments
- Educational materials & Demo/evaluation units
- Coupons, vouchers and discount cards
- Charitable contributions
Complete and submit the Compliance Officer Form by January 1st of each reporting period with a registration fee of $500. Email completed Excel spreadsheets for both Expenditure and Sample disclosures to ago.disclosures@vermont.gov
FDA Sample Report
Section 6004 of the Affordable Care Act — Drug Sample Reporting
Manufacturers and authorized distributors of applicable drugs must submit the identity and quantity of drug samples requested and distributed, aggregated by:
- Name, address, professional designation of the practitioner who made the request
- Signature of the practitioner or their designee for receiving samples
Data points to be disclosed: Submission year, Business name, Practitioner professional designation, First/middle/last name, Address, Drug trade name and dosage, Package size, Package/quantity requested, Package/quantity received, Signature received.
When a manufacturer and authorized distributor of record (ADR) both have records regarding the same drug sample request or distribution, only one of the two entities should submit the required information to FDA.
- Sign up for an Electronic Submissions Gateway account at fda.gov/ForIndustry/ElectronicSubmissionsGateway
- Submit reports in XML format to FDA via Gateway. Download the XML schema at fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/ucm292040.htm