What the 2025 Open Payments Data Means for Your Practice, and What to Check Before December 31

Every rep lunch, every speaker program dinner, every consulting fee a physician receives from a drug or device company ends up in a public federal database. Most practices know this in a general way. Far fewer have ever looked at what's actually listed under their providers' names.

This summer, the Centers for Medicare & Medicaid Services (CMS) published the 2025 Open Payments data, and it set a record. For practices, it's also a reminder that there's a window to review and correct those records, and it closes at the end of the year.

Here's what office managers and practice administrators should know.

What Open Payments is

Open Payments was created under the Physician Payments Sunshine Act. It requires drug and medical device manufacturers to report payments and other "transfers of value" they make to healthcare providers. CMS then publishes that information in a searchable public database at openpaymentsdata.cms.gov.

The program covers more than physicians. Since 2021, reporting has also included physician assistants, nurse practitioners, clinical nurse specialists, CRNAs, and certified nurse-midwives. If your practice has any of these providers, their records are in the database too.

Anyone can search it: patients, journalists, employers, researchers, and competing practices.

The 2025 numbers

For Program Year 2025, CMS published $14.67 billion in payments and ownership interests across 17.07 million records, the highest annual total since data collection began in 2013. Those records are tied to:

• 667,898 physicians
• 362,261 non-physician practitioners
• 1,327 teaching hospitals

The total breaks down into three categories:

• $3.92 billion in general payments (meals, travel, speaking, consulting, and similar)
• $9.50 billion in research payments
• $1.25 billion in ownership or investment interests held by physicians or their immediate family

General payments rose 18.4% over the previous year. Among them, royalties made up the largest share at 30.7%, followed by speaking fees at 20% and consulting at 16.5%.

Most practices won't see anything close to those big-ticket categories. But nearly every practice that hosts reps has something in the database, and that's where the review matters.

Yes, the rep lunch is in there

The part of Open Payments that affects the most practices is also the most routine: food.

When a rep provides a meal, the manufacturer reports its value for each covered provider who takes part. There is a small de minimis threshold. For 2025, individual items under $13.46 didn't need to be reported, unless a provider's total from that company for the year exceeded $134.54. In that case, every item gets reported regardless of size.

In practice, that means almost everything gets captured. A provider who attends a few lunches a month with several companies can build up dozens of line items over the course of a year.

None of this is improper. CMS itself states that a listed payment does not signify an inappropriate relationship, and Open Payments doesn't prohibit these transactions. But because the data is public, and because patients and others can read it without context, it's worth making sure it's accurate.

Why accuracy matters for your practice

Reporting errors happen. Manufacturers submit millions of records, often built from sign-in sheets, expense reports, and attendee lists that reps fill out in the field. Common problems include:

• Wrong provider. A payment attributed to a physician who wasn't there, or to the wrong physician with a similar name.
• Wrong amount. A meal cost split incorrectly, or a group lunch assigned in full to one person.
• Wrong date or duplicate entries. The same event reported twice.
• Wrong category. A routine meal reported as something that sounds more significant.

Each of these can leave a provider's public profile looking different from reality. For a practice, that can affect patient trust, credentialing questions, employer or health system reviews, and how the practice looks to anyone researching it.

The December 31 deadline

For the 2025 data, providers can review and affirm, or dispute, records in the Open Payments system through December 31, 2026. Updates made during that window are reflected in the next annual data refresh or a later publication.

Review is voluntary. But if no one at your practice looks, any errors will simply stay in the public record.

How to review your providers' records

Here's a simple process your practice can follow each year:

1. Start with the public search. Go to openpaymentsdata.cms.gov and search each provider by name. This shows you what the public sees, with no login needed. It's a quick way to spot anything that looks off.

2. Register for the review system. To formally affirm or dispute records, each provider (or an authorized person acting on their behalf) needs to register through CMS's Enterprise Portal and then in the Open Payments system. Registration takes some time, so don't leave it until the last week of December.

3. Compare against your own records. Pull your calendar of rep visits, lunch logs, and sign-in sheets for 2025. Check dates, attendees, and amounts against what's reported.

4. Dispute what's wrong. If a record is inaccurate, file a dispute in the system. The reporting company is notified and works with the provider to resolve it. Keep notes on what you disputed and why.

5. Affirm what's right. Affirming accurate records isn't required, but it creates a clear trail showing your practice reviewed the data.

6. Put it on the calendar. CMS publishes new data each summer. Make an annual review part of your practice's routine, the same way you'd handle credentialing renewals or license tracking.

Make next year's review easier

The practices that find this review painless are usually the ones that keep good records all year long. A few habits help:

• Keep a log of every rep visit. Date, company, rep name, which providers attended, and what was provided. This becomes your source of truth when it's time to compare.
• Use sign-in sheets consistently. Make sure only providers who actually attend sign in, and that names are spelled clearly. Many errors start right here.
• Assign one owner. Usually the office manager or a designated staff member. One person who knows the process beats everyone assuming someone else is handling it.
• Schedule visits deliberately. Practices with a structured approach to rep meetings, set times, a set number per month, and clear records of who met with whom, have far cleaner data to work from than practices where reps drop in unannounced.

That last point matters more than it might seem. When rep visits happen on an ad hoc basis, nobody has a reliable record of who came, when, or who attended. When visits are scheduled and documented, the Open Payments review becomes a quick comparison instead of a guessing game.

The bigger picture

Open Payments isn't going away. Every year the numbers get larger, the database gets more complete, and more people know how to search it. For practices, that means transparency is a permanent part of working with industry reps.

That's not a reason to avoid rep relationships. Reps remain a valuable source of information on new therapies, patient assistance programs, and formulary changes. It's a reason to manage those relationships with the same organization you'd apply to any other part of running a practice.

Med Sales Hub helps practices do exactly that. Practices create the meetings they want to host, reps are matched via AI, and every meeting is organized and on the record. If your practice wants a cleaner way to manage rep visits, from scheduling through closeout, we'd be glad to show you how it works.

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