The Centers for Medicare and Medicaid Services (CMS) recently published their 2020 Open Payments data as well as newly submitted and updated payment records for previous program years. The 2020 report includes transactions that took place between January 1st and December 31st. Applicable manufacturers reported $9.12 billion in reportable payments, ownership and investment interests to healthcare professionals (HCPs) and healthcare organizations (HCOs). The total amounts to approximately $900 million less than the previous reporting year. Over 1,600 companies reported a total of 6.38 million records attributable to 487,000 physicians and 1,213 teaching hospitals.
For reporting purposes, payments are broken down into three categories:
- General
- Research
- Ownership and Investment Interests
According to the data published by CMS, $2.03 billion was attributed to general payments. Research payments totaled $5.97 billion, while ownership and investment interests accounted for $1.12 billion.
The above graphic illustrates the decline in overall spend resulted from the general payments category, highlighted in red, which reported $1.53 billion less than 2019. Research and ownership spend amounts have maintained a sense of consistency over the past several years. Research payments, which accounted for the majority of spend, saw a slight increase during the 2020 calendar year. One inference that can be drawn from the published data is that despite the pandemic, many companies maintained their research, shifting their focus to Covid-19 related research including clinical trials related to Covid-19 tests, treatments and vaccines. Published study names included identifiers related to Covid-19. The total impact of the pandemic on research may not be entirely clear for years because CMS allows for manufacturers to delay publication of certain research related payments for up to four years.
The decrease in general payment spend is evidence of the effect that Covid-19 had on the industry during the last year. In-person interactions, such as lunch and learns and live educational conferences came to a halt during the first quarter of 2020. As an example, when comparing the data, the percent of “food and beverage” payments decreased by almost 50% from 2019. Entertainment, travel and lodging, as well as compensation for serving as a faculty member at events were also significantly down. The correlation between the large decrease in general spend and the pandemic is supported below by the significant drop is spend value during February and March of 2020 when the country and activities began to shut down. The gradual increase in food and beverage towards the latter months of the year likely indicate transfers of value made as companies began to host more virtual events.
One important thing to keep in mind is that 2020 was also the last year in which transfers of value were only be reported for physicians and teaching hospitals. Program year 2021 data, which will be published in June of 2022, will include the newly added covered recipients:
- Physician Assistants
- Nurse Practitioners
- Clinical Nurse Specialists
- Certified Registered Nurse Anesthetists
- Anesthesiologist Assistants
- Certified Nurse Midwives
It will be interesting to see how the expansion of covered recipients as well as the long-term impacts of Covid-19, including the changes that many companies have made to their policies around interactions with HCPs, affect the data reported for 2021.
The publishing of the 2020 Open Payments data along with the expansion of applicable covered recipients in the program serves as another reminder for companies to review their compliance policies and procedures related to HCP interactions. Ensuring accurate and complete reporting should continue to be a priority. To learn more how MediSpend can help support your Open Payments reporting obligations, please contact us.
The full set of CMS Open Payments data can be found here: https://openpaymentsdata.cms.gov/.
Lauren Howe
Compliance Attorney
July 14, 2021