WorkflowCompliance & Ethics

Open Payments Recipient Validation

Open Payments recipient validation that proves every NPI before the federal file

Every recipient matched to the right NPI and licence, with the evidence

See one case, screen by screen ↓
demo9recordsacross 3 systems fixed by one confirmed match — $14,860 to the right NPI
demo412matchesunresolved, counted on the submission clock — clear by Jan 18 at today's pace
target97.6%of payment records matched on their own, with the evidence on file
target2.6minmedian to decide an uncertain match, candidates side by side
In short

What is Open Payments Recipient Validation?

Checking that every payment or transfer of value in the federal Open Payments report is attributed to the right covered recipient — the right NPI, licence state and recipient type. Open Payments Recipient Validation does it with six agents that find and score every candidate, cite the evidence and route the uncertain matches to a transparency analyst.

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Updated

The problem

Why one hand-written name can cost an analyst twelve minutes

Every payment or transfer of value to a US physician, non-physician practitioner or teaching hospital has to reach the federal Open Payments report against the right covered recipient: the right NPI, licence state and recipient type. The payments arrive from the expense, events, contract, research and grants systems with the name as a rep wrote it — and “Dr. J. Smith” fits three people in one city. For the records rules cannot settle, a transparency analyst searches the NPI registry and the state board by hand and pastes screenshots into a spreadsheet.

The risk sits in the calls nobody wrote down. Since program year 2021 physician assistants, nurse practitioners, clinical nurse specialists, CRNAs and certified nurse-midwives are covered too, so a sign-in that says “RN” or “Midwife” can hide a reportable payment. Speaker programs peak in the third and fourth quarters, so the backlog grows just as the year closes. And in April every recipient can review and dispute their record — a match without a recorded reason becomes rework every spring.

typical$1,000–$10,000per paymentcivil money penalty for a payment reported wrong, late or incomplete — up to $100,000 when knowing
typical14.7Mrecordspublished for program year 2023, about $12.8 billion in payments
typical45daysfor recipients to review and dispute their records each spring, with 15 more to resolve
Where an analyst's hours go on 100 uncertain matchesestimated
By hand15 days
With the solution4.3 days
  • Finding the candidates in the NPI registry4 → 0.3 d
  • Checking the licence with the state board3 → 0.3 d
  • Comparing name, credential, specialty and address, and deciding3.5 → 3.2 d
  • Writing down the reason, with screenshots2.5 → 0.3 d
  • Correcting every record behind the payment and the HCP master2 → 0.2 d

Estimated split: 6–12 minutes a match by hand today, against the 2.6-minute median the solution targets for a person's decision.

How it works

How a payment moves

Six specialist agents find, compare and cite every candidate recipient; a transparency analyst confirms each uncertain match.

What comes in
Payments in5 payment systems · expenses, events, consulting, research, grants
Agents at work
Feed intake agentevery night
Then
Name & address normalisernames + addresses
Then
Registry matchercandidates side by side
Then
Covered-recipient classifierrecipient type
Evidence writernumbered citations
Then
Submission file builderpre-validated
A person decides
Transparency analystdecides each uncertain match
What comes out
Matched recipients
Federal report file
Submission clock
One case, step by step

One payment, from “Dr. J. Smith” to the federal file

Northwind Bio ran a Corventa heart-failure advisory board in Columbus on Sep 12, 2026. The consulting agreement is signed “Dr. J. Smith”, and nine payment records across three systems — $14,860 — have no NPI. Here is what happens next, screen by screen, in the working solution.

  1. 01Wednesday morning

    Her exceptions, and the clock, on one screen

    Lena Ortiz · Transparency reporting analyst

    Lena has 15 exceptions assigned to her; the team has 412 matches unresolved across 3,068 records, and the window opens Feb 1 — 117 days out. At the top of her list: M-2039, an advisory board contract, 9 records, $14,860, due Oct 9. The agents recommend Jennifer L. Smith, MD, NPI 1427093318, at a match score of 92%.

    “Below the 0.95 line a person decides.”

  2. 02Overnight, in seconds

    41 Smiths in Ohio, three in Columbus

    The agents

    The name and address normaliser kept the initial “J.” as a partial first name and set “Dr” aside. The registry matcher found 41 Smiths in Ohio and 3 with the initial J in Columbus. The licence check and the address check each point to candidate A, the covered-recipient classifier reads specialty code 207RC0000X as a physician, and the evidence writer writes the reason with numbered citations.

    Score 0.92 is below the 0.95 auto-match line, so the match is routed to Lena Ortiz.

  3. 03Candidates side by side

    Licence and address settle it

    Registry matcher

    Each field of the payment record sits beside each candidate, marked agrees, variant or differs. The name and the credential cannot decide it. The practice address and the licence can: 2200 Riverside Dr and OH 35.098214 agree with candidate A and differ for James R. Smith, an internist on Knightsbridge Blvd, and Julia M. Smith, an adult-health nurse practitioner.

    “Her practice is 2200 Riverside Dr, Suite 300 — the address on the contract.”

  4. 04One click on a cell

    The Ohio board, at the passage

    Lena Ortiz · Transparency reporting analyst

    Lena clicks the licence and the evidence panel opens the state licence lookup: Jennifer Lynn Smith, MD, licence type Physician (MD), number 35.098214, active, expiring Jul 1, 2027, at 2200 Riverside Dr, Ste 300, Columbus. The consulting agreement CA-26-0918, the registry records and the HCP master record HM-140 377 are one tab away.

    “Looked up live at the board or registry; the lookup is kept with the decision.”

  5. 05Confirmed

    Nine records carry the right NPI

    Lena Ortiz · Transparency reporting analyst

    Lena confirms the match. The NPI is written onto all 9 records in consulting contracts, speaker programs and expenses & meals. A master-data fix — link licence OH 35.098214 and NPI 1427093318 to HM-140 377 — goes to Dana Okafor. The profile is pre-validated against the federal profile rules with 0 errors and added to the submission file, program year 2026, batch 41.

    “9 records across 3 systems now carry NPI 1427093318 · physician. Decided by Lena Ortiz.”

  6. 06The submission clock

    411 unresolved, and the pace to clear them

    Lena Ortiz · Transparency reporting analyst

    Her decision takes the count to 411 matches across 3,059 records. In the last 30 days the team decided 36.8 matches a day while 39.7 a day were opened. At today's pace the last match is decided on Jan 18 — 10 days after the Jan 8 year-end pre-validation. Expenses & meals holds 168 of the unresolved matches, speaker programs 131.

    What closes the gap: “4 more decisions a day — about one more per reviewer each day, starting now.”

  7. 07Next exception

    Every exception says why it needs her

    Lena Ortiz · Transparency reporting analyst

    Her list is sorted by due date, with the reason each payment needs a person: a name variant, two people who fit, a credential unclear, an NPI deactivated, a payment to a practice or a foundation. Each row shows the source systems, the records and value behind it, the agents' confidence and the stage. A foundation grant and a duplicate master record also need a second person's sign-off.

  8. 08A second person

    An $85,000 grant to a foundation

    Omar Haddad · Aggregate spend operations lead

    M-2047 is a fellowship grant paid to Lakeview University Medical Center Foundation, a separate charity with its own tax ID. The grant agreement directs the funds in full to the hospital for two fellowship positions, and the hospital is on the program-year 2026 teaching-hospital list. The agents recommend reporting it to the teaching hospital, at 81% — and teaching hospitals are never auto-matched.

    “This kind of call needs Omar Haddad's sign-off.”

  9. 09Every night

    4,812 payments matched before morning

    The agents

    Last night five source systems sent 4,812 payment records. The registry matcher found a candidate for 4,790 and looked up 298 licences; the evidence writer wrote 1,206 citations. 4,671 records were matched on their own and added to the submission file with 0 profile errors; 141 went to reviewers, 15 of them to Lena.

    Matched on their own: score ≥ 0.95, no rule hit.

  10. 10In April

    A dispute, answered from the record

    Sam Patel · Director, healthcare compliance

    When a recipient disputes a payment in the review period, the recipient's profile holds every record behind it, by nature of payment and by month, with who matched it and when. Dr. Daniel Osei's 39 records, $31,800, were matched by Lena Ortiz on Oct 2 and his Georgia licence verified Oct 5. One click exports the evidence pack.

    Each decision keeps its evidence for at least five years after publication.

Who it’s for

Built for everyone who answers for a recipient.

The same payment, seen by the four people who carry it — what their reporting year looked like, and what it looks like now.

LO
Lena OrtizTransparency reporting analyst · works the exception queue
Transparency reporting analyst
Before
“Three J. Smiths in Columbus. I need the one on the contract, and proof I picked right.” Searches the NPI registry and the state board by hand for every one.
Now
Opens each exception with the candidates side by side, the deciding fields marked and the reason cited; one confirmation fixes every record behind the payment.
OH
Omar HaddadAggregate spend operations lead · signs off the riskiest calls
Aggregate spend operations lead
Before
“In April a doctor will dispute this. I want the reason on file today.” Owns the auto-match line and every teaching-hospital and not-covered call.
Now
Signs off teaching-hospital, foundation and not-covered decisions with the evidence on one screen, and watches the submission clock against the February window.
DO
Dana OkaforHCP master-data steward · merges and fixes master records
HCP master-data steward
Before
“Send me the fix with the evidence and I'll make it once.” Finds duplicates and stale credentials after they have already caused exceptions.
Now
Receives every credential, address and duplicate fix found while matching, with its evidence, as a proposal she applies to the HCP master.
SP
Sam PatelDirector, healthcare compliance · reads everything, exports evidence
Director, healthcare compliance
Before
“Show me who decided, when, and on what.” Rebuilds the story behind a payment from spreadsheets when a recipient or an auditor asks.
Now
Opens any recipient's profile and exports an evidence pack: every record, the registry and licence lookups at the time of the match, who decided and why.
Built on the engine

6 agents. Each with one job, and hard limits.

Six specialist agents find, compare and cite every candidate recipient; a transparency analyst confirms each uncertain match.

Feed intake agent

Pulls the nightly payment batch from the expense, events, accounts-payable, grants and clinical-payment systems, labelling each line's source system, nature of payment, product and amount, with the recipient kept exactly as captured.

  • Never edits a source system
  • Rejects a batch with a broken record count
Name & address normaliser

Splits names, sets credentials aside, records nicknames and former names as variants, and standardises addresses — suites and ZIP+4.

  • Never guesses a credential
  • Keeps the as-captured value next to every cleaned value
Registry matcher

Finds every plausible candidate in the NPI registry, state licence lookups, the HCP master and the teaching-hospital list, and scores name, credential, specialty code, address, licence and NPI separately — the licence number before the name when both exist.

  • Exact NPI, licence and name for an auto-match, at 0.95 or above
  • Never auto-matches a teaching hospital
Covered-recipient classifier

Decides physician, physician assistant, nurse practitioner, clinical nurse specialist, CRNA, certified nurse-midwife, teaching hospital or not covered — from the registry specialty code and the licence type, not the credential the business typed.

  • “Not covered” always needs a sign-off
Evidence writer

Writes the short reason for each match, in 3–5 sentences, with numbered citations to the exact registry, licence and source passages, and says what the person must decide.

  • Every claim cites a passage
  • Plain words — no codes without a meaning
Submission file builder

Writes confirmed recipients into the federal file layout and pre-validates NPI, licence and name against the federal profile file, reporting any profile error back to the exception list.

  • Only confirmed records enter the file
Transparency analyst

Decides each uncertain match. The agents propose; a named person decides.

Ask in plain words

Ask about any recipient, in plain words

Ask about any recipient, exception or source system — or say which matching rule to add. Every answer points to its source.

Why Jennifer L. Smith and not the other two?

Because the licence and the address both point to her. The contract gives Ohio licence 35.098214; the Ohio board lists that licence for Jennifer Lynn Smith, MD, and her practice is at 2200 Riverside Dr — the address on the contract. James R. Smith is an internist on Knightsbridge Blvd; Julia M. Smith is a nurse practitioner. The name alone could not decide it, so you confirm. Confirming fixes 9 records worth $14,860.

How ready are we for the February submission?

Close, but not yet on track. 117 days until the window opens on Feb 1, 2027; files must be attested by Mar 31. 412 matches are unresolved; at today's pace the last is decided on Jan 18, 10 days after year-end pre-validation — 4 more decisions a day closes the gap.

Which practitioners count as covered recipients?

Besides physicians and teaching hospitals, five non-physician practitioner types have been covered since program year 2021: physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists and certified nurse-midwives. Registered nurses and pharmacists are not covered. Two of your open exceptions are credential mix-ups: an “RN” who is a CRNA and a “Midwife” who is a CNM.

How do you handle teaching hospitals?

Teaching hospitals are matched only against the CMS list for the program year — never auto-matched. In M-2047 the payee is the hospital's foundation, a separate charity, but the grant agreement sends the funds to the hospital's fellowship, and the hospital is on the 2026 list. The agents recommend reporting it to the hospital; Omar Haddad signs off.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

Recipient matchThe analyst's exceptions, the submission clock, and the recommended match with every candidate side by side.
How the agents matchedEach agent's step in order — normalise, find candidates, check the licence and address, classify, cite — with its timing.
The fields that settle itAgrees, variant or differs for every field, the rows that decide the match, the cited reason and the master-data fix.
The licence lookupThe state board record at the passage the reason cites, kept with the decision.
Confirmed and filedOne confirmation writes the NPI onto every record, sends the master fix, pre-validates the profile and adds it to the submission file.
Submission clockUnresolved matches against the dates that matter, week by week, with the pace that clears them by year-end pre-validation.
Where every payment goesEvery record of the program year by source system and outcome, the reporting calendar and the penalty for a wrong record.
ExceptionsEvery payment that needs a person, with the reason, source systems, records, value, confidence, stage and due date.
Teaching hospital sign-offA grant paid to a foundation, reported to the listed teaching hospital, sent for a second person's sign-off.
Recipient profileOne verified identity with payments by nature and month, every record behind it, and the evidence pack.
The nightly runFive source systems, each agent's count, what matched on its own and what went to a person, and recent nights.
DashboardRecords received, the share matched on their own by source system, who was paid, and why payments need a person.
Your rulesThe auto-match line, matching switches, sign-off owners, matching rules, reference data and people.
Governance

Built for the federal report: cited, signed off, on the record.

Every match cites its passagesEach reason cites the registry record, the licence lookup, the source record and the master record it relied on, and every cell in the comparison opens its source.
Below the line, a person decidesA match is confirmed on its own only at a score of 0.95 or above, with exact NPI, licence and name and no rule hit. Everything else goes to a transparency analyst with the candidates side by side.
A second person on the riskiest callsTeaching hospitals and foundations, “not a covered recipient” and duplicate master records each need a named person's sign-off before they reach the file.
Registries and the master are read, never editedThe agents never edit a source system, a registry or the HCP master. Credential, address and duplicate fixes are proposals the master-data steward applies.
Only confirmed records enter the fileThe submission file builder adds a record only once its recipient is confirmed, and pre-validates NPI, licence and name against the federal profile file first.
Every decision on the audit trailEach agent step, decision, sign-off, rule change and setting is recorded with who, what and when, and each decision keeps its evidence for at least five years after publication.
Configuration

Your matching policy, not ours

How the agents match, who signs off and where the reference data comes from are settings, on the audit trail.

SettingDefaultChoose from
Auto-match line0.95 — the line the compliance committee approved0.90 · 0.95 · 0.98
Send master-data fixes to the stewardOn — to Dana OkaforOn · Off
Licence before nameOnOn · Off
Teaching hospitals always need a personOnOn · Off
Confirm credential fixes on their own (RN → CRNA)OffOn · Off
Sign-off: teaching hospitals and foundationsOmar HaddadOmar Haddad · Dana Okafor · Sam Patel
Sign-off: not a covered recipientOmar HaddadOmar Haddad · Dana Okafor · Sam Patel
Sign-off: duplicate master recordsDana OkaforOmar Haddad · Dana Okafor · Sam Patel
Connections

Works with the systems your spend data already lives in

Spend transactionsexpense system, events platform, accounts payable, clinical payments and grants systems
HCP masteryour customer master of people and organisations, read live
NPI registrythe public weekly file, about 8.9 million providers
State licence lookups50 states and DC, looked up when a match needs them
CMS teaching-hospital listthe list for the program year, 1,327 hospitals
Federal profile filecovered-recipient profiles for pre-validation before submission
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
97.6%
of payment records matched on their own, with the evidence on file
matched without a person
target
2.6min
median to decide an uncertain match, candidates side by side
estimated
2–4people
freed from manual matching at about 1.8 million records a year
Today53k–88k reviews a year
With agents16k–26k

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures and regulation (42 CFR 402.105 — civil money penalties, before inflation adjustment; 42 CFR Part 403 Subpart I, §403.908 — the recipient review and dispute period; CMS Open Payments program-year 2023 data overview). People, companies, products, NPIs and addresses named on this page are fictional — characters and sample data in the working solution.

Questions

What transparency teams ask us.

What is Open Payments recipient validation?

Checking that every payment or transfer of value in the federal Open Payments report is attributed to the right covered recipient — the right NPI, licence state and recipient type. Open Payments Recipient Validation does it with six agents that find and score every candidate, cite the evidence and route the uncertain matches to a transparency analyst.

How does it match a payment to the right NPI?

The registry matcher scores every candidate from the NPI registry, state licence lookups, the HCP master and the teaching-hospital list, field by field: name, credential, specialty code, address, licence and NPI. A licence number is matched before the name. At 0.95 or above, with exact NPI, licence and name and no rule hit, the match is confirmed on its own; below it, a person decides with the candidates side by side.

Does it handle physician assistants, nurse practitioners and other non-physician practitioners?

Yes. The covered-recipient classifier decides physician, physician assistant, nurse practitioner, clinical nurse specialist, CRNA, certified nurse-midwife, teaching hospital or not covered from the registry specialty code and licence type — not the credential typed on a sign-in. A “not covered” decision always needs a sign-off.

How are teaching hospitals and foundations handled?

They are matched only against the CMS teaching-hospital list for the program year and are never auto-matched. When a grant is paid to a hospital's foundation, the agents read where the agreement directs the funds and recommend the reportable entity; a named person signs off.

Does the AI change our HCP master or source systems?

No. The agents read the source systems, the registries and the HCP master and never edit them. Credential, address and duplicate fixes found while matching go to the master-data steward as proposals, with their evidence.

Do people stay in control of the federal report?

Yes. Below the auto-match line a transparency analyst decides every match, the riskiest calls need a second person's sign-off, and only confirmed records enter the submission file. Every decision is on the audit trail with its evidence.

How do we know we will be ready for the submission window?

The submission clock counts the unresolved matches and records, the days to the window, the decisions made and opened each day, and the date the last match is decided at today's pace — with the extra decisions a day that clear it by year-end pre-validation.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your matching policy, your source system extracts and a sample of past payment records — and it goes live once every quality gate has passed. We will walk you through it on your own data first.

See it on
your spend data.

We'll run Open Payments Recipient Validation on a sample of your own past payment records.