Physician Payments Sunshine Act: Majority of Transactions in Open Payments Are Less Than $20

Many payments in the Open Payments website wouldn’t cover a doctor’s popcorn and soda, let alone a movie ticket. Out of the 2.6 million lines of identifiable general payments that manufacturers collected and reported to CMS about their interactions with physicians and teaching hospitals, approximately 1.7 million “transfers of value” were for less than $20. More than 1.2 million were for less than $15. 

Often these entries constitute the value of a meal–this could be a doctor’s bagel and coffee while listening to an educational event, or plated lunch while attending a conference. Meals and Beverages represented a vast majority of the smaller payments under $50.00 and comprised of 84% of the total number of payments made in the general identifable database.

Beyond the tremendous burden on manufacturers to track and record these payments (which CMS very conservatively put at $269 million for the first year, and $180 million annually thereafter), the fact remains that the database is overwhelmingly stocked with tiny payments to physicians. This chart shows the identifiable database for general payments:

The de-identified general payments category had a very similar breakdown, where close to one million lines of data–63.6 percent–were for payments of less than $20.

Looking forward to 2014–where 12 months instead of 5 months of data will be included in the database and all payments will potentially be identifiable–we can estimate that more than 6 million lines of data will represent payments of less than $20. 

We have followed the implementation of the Sunshine Act for many years, and understand the policies behind tracking certain payments from companies to doctors. We also recognize that meaningful policy also strikes a balance. Right now, one need only sift through the thousands of $0.80 payments to realize we have not quite gotten there.