Open Payments Program: CMS Publishes Program Year 2020 Data Showing Significant Reductions Due to Pandemic
On June 30th, the Centers for Medicare & Medicaid Services (CMS) published 6.38 million records, accounting for $9.12 billion in payments and ownership and investment interests. Over the past seven years, CMS has published over 78 million payments, accounting for over $67 billion in spend (excludes Program Year 2013 that has since been archived by CMS).
The data helps shed a light on how the COVID-19 pandemic impacted industry in-person interactions with health care professionals and associated research spend into treatments. The data also continues to show that reporting entities need to ensure they carefully review their data prior to submission and attestation, such as one applicable manufacturer that reported a $467,818 meal to a physician covered recipient.
This is also the last program year that covers payments or other transfers of value provided to physicians and teaching hospitals. Program Year 2021 will include physician assistants and advanced practice registered nurses.
General Payments
The general payments category is broken into 15 nature of payment types, such as food and beverage, honoraria, consulting fees, and royalties or licenses. In Program Year 2020, general payments represented 90% of all payments submitted, accounting for 22% of all spend.
Even amidst the COVID-19 pandemic, the number of food and beverage payments dominated the other payment types representing over 87% of the total number of payments reported (5.19 million out of 5.91 million). However, there was a significant decrease in the payments and amount submitted compared to Program Year 2019. The number of food and beverage records decreased by over 44% (from 9.42 million to 5.19 million) and the total amount of those payments decreased by 53% (from $246.04 million to $115.42 million). 
A brief review of some of general payments category shows that reporting entities are not reviewing their data prior to submission and attestation. For example, an applicable manufacturer that specializes in calcium compound devices to regenerate and repair bone and soft tissue reported six food and beverage transactions to a physician covered recipient, accounting for $700 thousand in food and beverage spend to a physician ($467,818; $147,882; $60,000; $13,000; $13,000; $13,000). Another applicable manufacturer that specializes in spinal implant devices and related products reported a $50 thousand food and beverage transaction attributed to a physician covered recipient.
Research Payments
Research payments continue to account for the majority of spend representing over 65% of spend for Program Year 2020 and over 56% of spend for all program years. Research payments also increased by 2.4% over the previous reporting period (from $5.83 billion to $5.97 billion).
We were also able to identify over $500 million in COVID-19 related research, accounting for over 8% of all research spend reported. This was based on a cursory review of applicable manufacturers that included a study name containing “COV”, “COVID-19,” “COVID,” “SARS-COV-2,” “SARSCOV.” It is important to note that COVID-19 research spend is far greater than the spend identified through our search and pertains only to those entities subject to reporting. A a full list of the reporting entities and associated study names submitted can be viewed here.
Ownership/Investment Interests
Reported spend related to ownership or investment interests decreased by over 17% compared to the previous program year (from $1.35 billion to $1.12 billion). Overall, two physician covered recipients accounted for over 43% of spend within this category.
ICU Medical Inc., a company that specializes in IV therapy products, systems, and services, reported that a director on the company’s board of directors, George A. Lopez, M.D., held an interest through stock or stock options valued at over $290 million. Midmark Corporation, a global manufacturer and supplier of healthcare products, equipment and diagnostic software for medical, veterinary, and dental markets, reported that an immediate family member of Robert C. Klamar, M.D., Anne Eiting Klamar (chair of Midmark’s board of directors) held common stock valued at over $198 million. The Open Payments Program requires reporting entities to report ownership or investment interests that are held by the physician or the physician’s immediate family members.