Last week, CMS posted the 2015 Open Payments data to its website, as well as updated payment records for 2013 and 2014.  Overall, manufacturers reported $7.52 billion in payments and ownership interests to 618,931 physicians and 1,116 teaching hospitals in 2015.  Nearly 1,500 companies reported making payments in 2015, comprising a total 11.9 million records.  Although the total number of records and amounts of payment are comparable from 2014 to 2015, there are shifts in the reporting of the nature of payments. 

On the heels of a recent JAMA-published study that suggested an association between industry-sponsored meals and physician prescribing patterns, we expect CMS and the U.S. Department of Justice to mine this new data for trends and enforcement opportunities.  For example, a CMS release observed that in 2015, “2.26 percent (637,131 records) of all financial transactions between physicians and pharmaceutical companies were related to opioid medications.”

The payments and ownership interests break down as follows:

• $2.60 billion in general (i.e., non-research related) payments
• $3.89 billion in research payments
• $1.03 billion of ownership or investment interests held by physicians or their immediate family members

CMS also published several charts summarizing basic analyses of the new data. Table 1, for example, summarizes payment trends in the industry.

Figure 1, below, summarizes the year-over-year change in reporting by nature of payment, and it reflects some dramatic shifts: more than double the reported amount of charitable contributions, as well as significant reductions in the value of reported honoraria, gifts, and education payments.

We would be happy to discuss ways that companies can efficiently review and analyze the new and “refreshed” data outside the government’s platform. Please contact our Sunshine Act team to learn more.