As required under the Massachusetts Pharmaceutical and Medical Device Code of Conduct Regulation (105 CMR 970.000), manufacturers must report certain payments and comply with annual registration requirements by July 1st of each year. Full regulatory details are available here: 105 CMR 970.000
Manufacturers must disclose any fee, payment, subsidy, or other economic benefit valued at $50 or more provided to a Massachusetts Covered Recipient, unless the payment is already disclosed under federal reporting (e.g., Open Payments/Transparency reporting), in which case it is exempt from separate Massachusetts disclosure.
Important: The definition of a Covered Recipient under Massachusetts law differs from the federal definition and may include additional recipient types (e.g., certain healthcare practitioners such as PharmDs, and RNs). For more information, click here: MA Pharmaceutical Code of Conduct Requirements
Even if no reportable transactions occurred, manufacturers must still complete the following:
- Annual Registration Renewal
- Payment of the $2,000 Annual Fee
- Submission of a Disclosure Report or a Zero-Spend Disclosure
To submit a zero-spend disclosure, you must officially report via email. There is no special form or portal submission available.
- Email Address to send your notification: pharmameddata@massmail.state.ma.us
- CC: tardif@qpharmacorp.com, Katherine.periera@qpharmacorp.com, judy.fox@qpharmacorp.com
- Subject Line: “Manufacturer Name”, “Manufacturer Unique ID (CC####)” and “Disclosure Report 2025”
- Email Body:
“[Company Name] is a registered pharmaceutical/medical device manufacturer in Massachusetts.
For calendar year 2025, the company had no reportable payments or other economic benefits to covered recipients.
This email serves as our disclosure submission for the reporting year.”
May 26, 2026 State of Massachusetts Regulatory Alert
All renewals and payments must be completed online prior to July 1, 2026:
- Online Registration Portal: If you have not previously done so, you will need to create an account (Massachusetts Department of Public Health eLicensing System) and link your Pharmaceutical Code of Conduct registration to it. Please see the ‘Creating an Account’ section of the Massachusetts user guide for instructions.
