What Data Elements are Published for Each Transfer of Value? (42 CFR § 403.904(c))

CMS publishes specific data elements for each reported “payment or other transfer of value” under 42 CFR 403.904(c). Even though manufacturers and GPOs do the reporting, small practices live with the public record and the reputational questions that follow. Knowing precisely what fields appear, how they are populated, and which documents substantiate them turns the annual Open Payments cycle into a controlled process.

At a minimum, published data capture who received value (identifiers like NPI, name, specialty, business address), what was transferred (amount, date, form and nature), why/for which product (associated drug, device, biological, or medical supply), and how the transfer occurred (direct/indirect, third-party context, charity designation), along with status flags such as delayed publication for certain research or dispute indicators. Anchoring operations to 403.904(c) lets a lean clinic validate entries fast, prepare clean disputes under 403.908, and avoid avoidable reputational friction.

“What exactly will the public see?” is the single most important question a small practice can ask about Open Payments. The answer lives in 42 CFR 403.904(c). That provision specifies the published fields for each transfer of value, shaping how patients, payers, and journalists interpret an entry. If a lunch, consulting fee, or research support appears beside your physician’s name, these fields talk for you, accurately or not, until you fix the record.

This tutorial turns the regulation into a practical blueprint. You will see how to build a Field Map that mirrors 403.904(c), attach evidence for each element, and execute a brief, targeted reconciliation before the review window. When something is wrong, you’ll reference the correct element, attach the corresponding artifact, and use 42 CFR 403.908 to dispute quickly.

Legal Framework & Scope Under 42 CFR 403.904(c)

What 403.904(c) does.
 Section 403.904(c) prescribes the data elements CMS publicly posts for each general payment, research payment, or ownership/investment report filed by applicable manufacturers and GPOs. For payments/transfers of value, the published set typically includes:

• Recipient identifiers: physician’s legal name; NPI (if applicable); professional credentials or specialty; state license number and state; and primary business address. These align with definitional terms in 403.902.

• Payment specifics: total amount, date (or date range if applicable), form of payment (e.g., cash or cash equivalent; in-kind items or services), and nature of payment (category such as consulting fee, food and beverage, travel/lodging, education, grant, charitable contribution, etc.) as enumerated by regulation.

• Product association: name(s) of any related covered drug, biological, device, or medical supply (as applicable).

• Third-party and charity indicators: whether the payment was made via a third party, at the request of a covered recipient, or designated to a charity, and the name of such entity where the rule requires.

• Research adjuncts and flags: when a payment is within the research category, additional research descriptors are published consistent with 403.904 and 403.906 (e.g., study/research context), and entries may display a delayed publication status if properly flagged by the filer under 403.906.

• Status metadata: dispute/correction indicators that flow from 403.908 activity.

Federal baseline; no state override.
 Open Payments is a nationwide federal program. While states or institutions may impose additional disclosures, those do not change the 403.904(c) publication fields themselves. State or institutional processes are parallel obligations.

Why it matters.
 Because these data are public, your best guardrail against confusion and reputational risk is to validate each element against your own artifacts, before publication where possible and via 403.908 if issues surface later.

Administrator: CMS runs the submission system, validates files, posts public data, and operates the review, dispute, and correction workflow under 42 CFR 403.908. Manufacturers/GPOs must submit complete and accurate datasets conforming to 403.904, and CMS publishes the subset specified in 403.904(c).

Clinic-facing triggers:

• Clinician notifications of pre-publication data to review particular fields, e.g., a wrong NPI or specialty, a mis categorized nature entry, or an associated product mismatch (all published under 403.904(c)).

• Filer data calls asking clinics to confirm details for identity matching or to clarify whether a transfer is tied to a covered product (affects published product fields).

• Media/payer questions about an entry’s amount, product tie, or context; the clinic must point to the exact field and show what the underlying record proves.

Your operational posture is to treat each 403.904(c) element as auditable: identify its internal source, validate it, and be ready to show your proof.

Below are lean controls tied to 42 CFR 403.904(c) that a small clinic can run without new headcount. Each includes implementation steps, evidence to retain, low-cost methods, and the regulatory anchor.

Control 1. Build a “Field Map” that mirrors 403.904(c) one-to-one

How to implement. Create a spreadsheet with a row for every published field under 403.904(c) (recipient identifiers, payment amount/date, form, nature, associated product, third-party/charity indicators, research flags, and status). Add three columns: Clinic Source (e.g., HR credential file, W-9, credentialing system), Filer Source (if known), and Evidence Path (file name or link).

 Evidence to retain. NPI registry printout, state license screenshot, specialty designation from credentialing, payment confirmation (remittance, check copy, invoice), event agenda, sponsor notice, and product references.

 Low-cost method. Use a single protected Google Sheet; restrict edit rights to a compliance lead.

 Authority. 42 CFR 403.904(c) (defines the published elements you mirror).

Control 2. Lock identity fields before anything else

How to implement. Reconcile each physician’s name format, NPI, license number/state, specialty, and business address to your HR/credentialing records so they match what CMS will display. Small mismatches cause mis attribution.

 Evidence to retain. Credentialing snapshots and NPI registry confirmations with dates.

 Low-cost method. Quarterly 10-minute checks; track deltas on the Field Map.

 Authority. 42 CFR 403.904(c) (recipient identifiers).

Control 3. Tie “form” and “nature” of payment to specific documents

How to implement. For each likely transfer, capture form (cash vs. in-kind) and nature (regulatory category) at intake using the manufacturer’s communication or event materials. If the item is in-kind, ensure the description is precise enough to withstand publication.

 Evidence to retain. Emails/letters stating the item, invoices listing in-kind services, shipping docs for equipment, agendas for meals/education.

 Low-cost method. Add a short intake question set: “Form? Nature? Proof?” and paste the proof into your evidence folder.

 Authority. 42 CFR 403.904(c) (published form and nature).

Control 4. Validate associated product links early

How to implement. Where a transfer relates to a covered drug, biological, device, or medical supply, note the product name(s) exactly as the manufacturer will use them. If your clinician spoke on broad disease topics rather than a specific product, document that distinction.

 Evidence to retain. Event description, slides showing generic topics, or sponsor instruction naming the product.

 Low-cost method. A one-line field in your intake form, “Associated product(s)?”, with a yes/no toggle and a text box.

 Authority. 42 CFR 403.904(c) (published associated product field).

Control 5. Capture third-party routing and charity designations verbatim

How to implement. If a payment passes through a third party or is designated to charity, collect exact language indicating whether it was at the request of the physician or designated on behalf of the physician. These distinctions publish.

 Evidence to retain. Third-party invoices with sponsor attribution, letters confirming charity designation, and emails showing who directed the routing.

 Low-cost method. A three-question email template sent to the organizer immediately after the event.
 Authority. 42 CFR 403.904(c) (third-party/charity indicators); 42 CFR 403.902 (definitions supporting routing concepts).

Control 6. For research, pre-stage the delayed publication logic

How to implement. If the transfer is research, confirm whether the manufacturer intends to flag delayed publication consistent with 403.906. Note study identifiers and the expected delay window, so public appearance timing will not surprise the clinic.

 Evidence to retain. Contract clauses on confidentiality/blinding and sponsor communication on delay.

 Low-cost method. Add a “Research/Delay” mini-tab to the Field Map for studies touching your clinic.

 Authority. 42 CFR 403.904(c) (published research fields/flags); 42 CFR 403.906 (delayed publication).

Control 7. Build dispute-ready packets organized by data element

How to implement. For any entry likely to be erroneous, assemble a packet with a cover sheet listing the exact 403.904(c) field(s) in error, the correction, and the exhibit proving it. This lets manufacturers fix the right element fast.

 Evidence to retain. Cover sheet, numbered exhibits, and final CMS screenshots showing correction.

 Low-cost method. A re-usable one-page template and a “Dispute Exhibits” folder per clinician.

 Authority. 42 CFR 403.908 (review, dispute, correction anchored to published elements in 403.904(c)).

Playbook wrap-up: These controls translate 403.904(c) into a simple discipline: know each published field, pair it with evidence, and keep a dispute kit aligned to those exact elements.

Case Study

Scenario (de-identified): A cardiology practice sees a $1,900 entry tied to a dinner program where their interventionist presented general clinical guidelines. The public record lists form = cash, nature = “consulting fee,” and associated product = a specific coronary stent. The clinician insists it was a meal with no product focus and that the payment was an in-kind dinner, not a cash fee.

What went wrong (through the lens of 403.904(c))

• The form was reported as cash, but the clinic’s records show a catered meal paid by the sponsor (in-kind).

• Nature was reported as consulting fee, but the event materials describe a general education/meal.

• Associated product lists the sponsor’s stent, yet slides and agenda show no product discussion.

Clinic action using the Playbook

1. The compliance lead opens the Field Map row for the dinner entry and pulls three exhibits: the event invitation specifying sponsor-paid dinner, the catering invoice naming the organizer, and the agenda showing no product mentions.

2. They file a dispute that calls out the precise 403.904(c) elements: “Form,” “Nature,” and “Associated product.” The brief proposes corrections, attaches the exhibits, and cites 403.908.

3. The manufacturer updates the record: form = in-kind; nature = food and beverage; associated product = none. The changes publish in the next refresh.

Outcome: The practice avoided a misleading implication of a cash consulting fee for a specific product. The clinic added a step to require a sponsor’s post-event summary whenever a physician presents at externally organized dinners.

Checklist wrap-up: These six tasks hard-wire the 403.904(c) publication fields into your routine, making disputes faster and reducing public-facing errors.

Risk Traps & Fixes Under 42 CFR 403.904(c)

Because 403.904(c) defines what the public sees, small slips create big misunderstandings. The following traps pair each error with the legal reference and its consequence.

• Conflating “form” with “nature.”
   Fix: Record form (cash vs. in-kind) and nature (regulatory category) separately at intake per 403.904(c); do not let a single email summary drive both fields.
   Consequence: Prevents entries that look like cash consulting when they were actually in-kind meals.

• Letting identity mismatches persist.
   Fix: Reconcile NPI, license numbers/states, specialty, and address routinely against credentialing; these identifiers publish under 403.904(c).
   Consequence: Reduces misattributed payments and downstream payer questions.

• Accepting the filer’s associated product without review.
   Fix: Document whether the event or payment truly related to a covered product; if not, request correction to the associated product field.
   Consequence: Avoids the appearance of product-tied influence when content was general.

• Ignoring third-party/charity indicators.
   Fix: Obtain written confirmation of direction/designation and ensure the third-party and charity indicators align with facts per 403.904(c).
   Consequence: Prevents confusion about whether value went to the clinician or a charity.

• Treating research timing as a black box.
   Fix: For research entries, track delayed publication expectations under 403.906 and verify the flag; do not dispute a public research entry that has reached the delay expiration.
   Consequence: Focuses disputes on correctable fields rather than timing the clinic can’t change.

• Submitting disputes without exhibits.
   Fix: Organize exhibits by the exact 403.904(c) element (e.g., “Form – Exhibit A,” “Nature – Exhibit B”) to speed manufacturer correction via 403.908.
   Consequence: Shortens resolution time and limits back-and-forth.

Wrap-up: Addressing these traps ensures your clinic’s evidence directly targets the published fields, which is the fastest way to correct what the public sees.

Lean teams win with rhythm, not headcount. Assign one compliance lead to own the Field Map and the calendar. Name one delegate per clinician with working portal access. Train for 15 minutes each quarter on (1) the published 403.904(c) elements, (2) where your clinic stores the evidence for each, and (3) how to assemble a dispute packet in under 20 minutes.

Track two simple metrics: (a) percentage of clinicians with validated identifiers and an updated Field Map row (target: 100%), and (b) average days from notification to dispute submission with complete exhibits (target: ≤3 business days). These numbers demonstrate controlled operations if anyone asks how you manage Open Payments visibility.

Your clinic cannot control what a manufacturer uploads, but you can control how quickly you verify and, if needed, correct the published fields under 42 CFR 403.904(c). A one-page Field Map, disciplined evidence capture, and dispute packets organized by data element turn the annual cycle from stressful to routine. The result is fewer surprises, cleaner public profiles, and less time spent on avoidable clarification.

Immediate next steps for a small clinic:

1. Stand up the Field Map: Create the spreadsheet mirroring 403.904(c) and populate identity rows for each clinician this week.

2. Hard-lock identity: Reconcile NPI, license/state, specialty, and address to credentialing files, so the public record can’t misattribute payments.

3. Intake discipline: Add three intake questions to every vendor interaction, Form? Nature? Associated product?, and paste the proof into your evidence folder.

4. Third-party proof: For any routed or charitable items, send the three-question verification email and file the replies under the correct Field Map row.

5. Dispute kit: Adopt the one-page dispute template keyed to 403.904(c) fields so you can resolve errors rapidly during the review window under 403.908.

• 42 CFR 403.904 — Reports of payments or other transfers of value and of physician ownership or investment interests
  

• 42 CFR 403.902 — Definitions (Open Payments)
  

• 42 CFR 403.906 — Delayed publication of payment or other transfer of value for research
  

• 42 CFR 403.908 — Procedures for review, dispute resolution, and corrections
  

• 42 U.S.C. 1320a-7h — Transparency reports and reporting of physician ownership or investment interests