The 2027 Open Payments calendar for compliance officers

A COI office does not set the Open Payments calendar, but it can plan the year around it. The dates below follow the cycle CMS publishes on cms.gov and in its User Guide for Covered Recipients (January 2026, section 1.1d). CMS had not announced dates specific to program year 2026 when this page was written, so the 2027 dates are expected, based on the standing cycle. Check cms.gov before you send a date to your medical staff.

The year at a glance

1. January 2027
   Data refresh. CMS republishes program year 2025 and earlier years with corrections made after the 2026 correction period: disputed records through December 31, 2026, and undisputed edits up to a cutoff in November.
   For the COI office: Re-run last year's reconciliation against the refreshed file. Note what moved.
   Expected, based on the standing cycle.
2. February 1 to March 31, 2027
   Companies submit and attest to program year 2026 data. Nothing is visible to clinicians yet.
   For the COI office: Confirm roster NPIs. Remind clinicians that registering with CMS takes time, and that registration is open year-round.
   Expected, based on the standing cycle.
3. April 1 to May 15, 2027
   Review and dispute window for program year 2026. Clinicians and teaching hospitals can see what was reported about them before it is published.
   For the COI office: Prompt clinicians to look. A record disputed and corrected now is right in the first publication.
   Expected, based on the standing cycle.
4. Through May 30, 2027
   Correction period. Companies can resolve disputes, and the first publication reflects the record as it stands at the end of this period.
   For the COI office: Follow up on open disputes your clinicians told you about.
   Expected, based on the standing cycle.
5. On or by June 30, 2027
   Program year 2026 is published, and prior years are republished.
   For the COI office: Reconcile attestations against the program year 2026 record. Report status to the committee.
   Expected, based on the standing cycle.
6. May 15 to December 31, 2027
   Clinicians can still review and dispute, and companies can still correct. These changes appear in the January 2028 refresh, not the June publication.
   For the COI office: Track late disputes. Expect some records to change in January.
   Expected, based on the standing cycle.

Two program years are live at once

In January 2027 you are looking at program year 2025, refreshed. From April you are looking at program year 2026, before it publishes. A plan that names the program year in each step avoids the most common mix-up, which is checking a clinician's attestation against the wrong year.

The 45 days that matter most

The review window (at least 45 days, April 1 to May 15 in the standing cycle) is the only stretch when a clinician can have a wrong record fixed before it is first published. A dispute raised after May 15 still counts, but the June publication shows the record as it stood at the end of the correction period, and the fix waits for a later publication. Only the covered recipient can file the dispute, in the CMS system, directly or through an authorized representative they nominate. The office's part is to make sure they look in time.

Lining up your own attestation cycle

Many COI offices collect annual attestations on their own schedule. Whatever that schedule is, two dates make the comparison cleanest: just after June 30, when a new program year is public, and just after the January refresh. The method is on how to reconcile COI disclosures against Open Payments, and the wider program is on monitoring Open Payments. If you are choosing software to run the cycle, start from the COI software checklist. To see what the public record holds for a hospital's medical staff today, look it up in the hospital directory.