Instructions for disclosure report creation

Learn how to create and properly format disclosure reports for submission to the Pharmaceutical Code of Conduct.

CSV formatting

The disclosure report must be sent in a comma-separated value format, or CSV. A CSV is a delimited text file that uses a comma to separate values, and can be viewed as a spreadsheet; many spreadsheet programs, such as Microsoft Excel, can create CSV files. Each row of this file will represent total payments to a particular covered recipient within a particular payment category. The following fields are required for each row:

  • Company ID: Each company who submits an initial compliance form and fee to DPH will be assigned a unique company ID by MA DPH. This ID will start with a “CC” prefix, and be followed by 4 digits. Field length is 6 characters; data type is character.
  • Covered Recipient ID: This is a unique ID assigned to each covered recipient (such as doctors, nurses, institutions, etc.). This ID is assigned by MA DPH and is located in the “List of Covered Recipients” spreadsheet which can be downloaded here (ZIP file). The “Covered Recipient ID” is the key field used by the Department when identifying a covered recipient. Inputting the wrong Covered Recipient ID into your disclosure report could result in misattribution on the Department’s public reporting website. As such, make sure you choose a correct and valid Covered Recipient ID. Field length is 6 characters; data type is numeric.
  • Covered Recipient Full Name: This is the full name of the covered recipient. This data must be pulled from the “Full Name” field in the department’s “List of Covered Recipients” spreadsheet. Field length is 50 characters; data type is character.
  • Category of Payment ID: There are several payment categories as defined by MA DPH. Each category has unique ID assigned to it. Field length is 4 characters; data type is numeric. These ID’s are listed here; they can also be found, along with their descriptions, on the department’s “Payment Category ID” spreadsheet detailed below.
    • 1000 – Compensation for Bona Fide Services
    • 2000 – CMEs, third-party Conferences, or Meetings
    • 3000 – Grants/Educational Gifts
    • 4000 – Food
    • 5000 – Education/Training
    • 6000 – Marketing Studies
    • 7000 – Charitable Donation
    • 8000 – Other
  • Amount of Payment: Companies have to report the amount of payments in US dollars. All figures should be rounded to the nearest dollar using standard rounding guidelines. This figure represents the sum total of payments to a particular covered recipient within a particular payment category. Field length is 10 characters; data type is numeric (representing whole US dollars).
  • Number of Events Reflected: This field represents the number of individual payment events that were provided to a particular covered entity for a particular payment category (for example: Company Y provides three lunches at $100 each to Dr. X – “amount of payment” = 300, “number of events reflected” = 3). If this field is left blank, it will be interpreted as “1.” Field length is 4 characters; data type is numeric.
  • Disclosure Reporting Period: As we enter the second year of disclosure report submissions, the Department now requires manufacturers to include the reporting period that a particular payment took place in. This is to give companies the ability to submit disclosure report data for previous reporting periods, and to make it clear which period the submitted data refers to. Please write in the year in a 4-digit format. For example, if a payment took place in the 2009 disclosure reporting period, write in “2009” in this field. The Department asks that manufacturers always include this field going forward. However, if this field is left blank, it will be assumed that the payment refers to the 2009 reporting period. Field length is 4 characters; data type is numeric.
  • License Type: This field represents the license type for the entity. This data should be pulled from the “LicenseType” column in the “List of Covered Recipients” file.
  • License Number: This field represents the license number for the entity. This data should be pulled from the “LicenseNumber” column in the “List of Covered Recipients” file.

Additional Resources for CSV formatting

Payment Disclosure Categories ID List

Unique ID Number MA Payment Category Name MA Payment Category Description
1000 Compensation for Bona Fide Services Consulting, Speaker's Bureaus, etc.
2000 CMEs, third-party Conferences, or Meetings Payments to CRs in Conjunction with CMEs, third-party conferences and meetings
3000 Grants/Educational Gifts Grants and Educational Gifts to CRs
4000 Food Meals Provided to CRs
5000 Education/Training Payments to CRs in Conjunction with education and training
6000 Marketing Studies Payments to CRs in conjunction with research other than genuine research
7000 Charitable Donation Donations other than donations of prescription drugs, biologics or medical devices
8000 Other Non-exempt payments to CRs of $50 or more

Additional Resources for Payment Disclosure Categories ID List

If you cannot find a covered recipient on the Covered Recipient List

The Covered Recipient List CSV file is over 250,000 rows. Due to its size, some programs, such as older versions of Excel, will not display the full contents of this file. If you encounter this problem, you can open the file with a database program, such as Microsoft Access, or a simple text editor such as Notepad.

Only entities licensed in Massachusetts are covered recipients under the regulation; thus, only Massachusetts-licensed entities appear in the covered recipient list. If you cannot find a professional in the list, you should first verify that the person is licensed in Massachusetts. The best method of doing this to ask the person themselves about their license status. However, Massachusetts also provides two online resources to check the license status of most health professionals:

The definition of a covered recipient is very specific. In the past, we have received questions on several entities that are not considered covered recipients in regards to this regulation. Below is a list of entities that are not covered recipients (please note: simply being one of the below classifications does not preclude the entity from being a covered recipient for other reasons):

  • Academic Institutions
    Schools and universities are not covered recipients. However, teaching hospitals are covered recipients, as they are hospitals, which are considered covered recipients.
  • Trade Organizations, Conference Organizers, and Non-Profit Charitable Organizations
    Unless they are covered recipients for other reasons (such as a non-profit hospital, which is a covered recipient by virtue of being a hospital) these entities are not covered recipients.
  • Corporations and other business structures
    Corporations are not covered recipients; however, corporations may own an entity that is a covered recipient. For example, a corporation that owns a hospital; payments made to the hospital would need to be attributed to the hospital, and not the corporation. 

Additional Resources for If you cannot find a covered recipient on the Covered Recipient List

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