CMS Open Payments 2025: $3.92B General and $9.50B Research by the Numbers

On June 30, 2026, the Centers for Medicare & Medicaid Services (CMS) published the Program Year 2025 Open Payments dataset, covering financial relationships between the biopharmaceutical and medical device industry and U.S. healthcare providers from January 1 through December 31, 2025. This annual release under the Physician Payments Sunshine Act (Section 6002 of the Affordable Care Act) represents the largest public database of financial transfers in healthcare.

For biopharmaceutical commercial teams, compliance officers, and market access executives, this dataset is far more than a regulatory transparency requirement; it is a critical source of competitive intelligence. Analyzing Open Payments data reveals competitor detailing intensities, speaker bureau investments, clinical trial support strategies, and key opinion leader (KOL) engagement patterns.

This trade briefing provides a detailed, reproducible analysis of the Program Year 2025 data. By aggregating the full 16,131,856 records in the general payments file and the 931,959 records in the research payments file, we analyze where the money went, which companies and products led the spending, and how these flows shape the market access landscape.

How much did manufacturers transfer in 2025, and how is the $14.67B split?

For Program Year 2025, reporting entities (applicable manufacturers and group purchasing organizations) submitted 17.07 million records documenting a total of $14.67 billion in financial transfers. This cumulative figure represents a significant increase compared to prior baselines, such as the Program Year 2022 total of $12.59 billion.

The Open Payments program separates financial transactions into three distinct tracking files: General Payments, Research Payments, and Physician Ownership or Investment Interests. The table below compares the Program Year 2025 totals with the Program Year 2022 historical baseline.

The data shows that research payments are the primary driver of spending growth, expanding by over 25% since 2022. While general payments (which cover detailing, speaker fees, consulting, food, and travel) are the most frequent interactions, research funding represents the vast majority of industry's financial relationship with the U.S. clinical system.

Covered recipient type: physicians, teaching hospitals, and non-physician practitioners

Within the $3.92 billion General Payments file, the recipient type reveals how manufacturers allocate their direct educational and promotional spending. In 2021, CMS expanded the definition of "covered recipient" to include non-physician practitioners (NPPs), specifically Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists, and Certified Nurse-Midwives.

Our aggregation of the 16.13 million General Payments rows reveals the following split by covered recipient type:

• Covered Recipient Physician: $2,624,554,750 (66.9% of general payments) across 10.13 million records.
• Covered Recipient Teaching Hospital: $1,028,480,609 (26.2% of general payments) across 35,569 records.
• Covered Recipient Non-Physician Practitioner (NPP): $270,515,604 (6.9% of general payments) across 5.97 million records.

Although physicians receive two-thirds of general payment dollars, the NPP segment represents nearly 6 million individual transactions. For market access teams, this reflects the growing clinical and prescribing autonomy of Nurse Practitioners and Physician Assistants, particularly in primary care and dermatology, where manufacturers invest heavily in food, beverage, and educational detailing.

Which companies paid the most in general vs. research payments?

A company-level analysis of Open Payments data exposes the commercial and clinical priorities of biopharmaceutical and medical technology firms. The entities that lead in General Payments (promotional detailing, speaker programs, and royalty arrangements) differ sharply from those that lead in Research Payments (sponsored clinical trials and translational research).

Top 15 manufacturers by General Payments volume (PY2025)

The table below details the top 15 reporting entities by total dollar volume in the General Payments file.

Top 15 manufacturers by Research Payments volume (PY2025)

Research payments reflect the clinical pipeline and postmarketing commitment (PMR) studies that support product evidence. The table below outlines the top 15 sponsors in the Research Payments file.

The BioNTech anomaly: mRNA royalty concentration

A striking finding in the Program Year 2025 General Payments file is that BioNTech SE is the single largest reporting entity at $536,410,036. Historically, the top spots in general payments were occupied by major U.S.-focused pharmaceutical detailing firms like AbbVie or Janssen. BioNTech, a German biotechnology firm with a limited U.S. field force, seems out of place.

This anomaly is explained by the Nature of Payment field. In the Open Payments dataset, the General Payments file includes licensing and royalty payments. BioNTech’s $536.4 million general payment total is driven almost entirely by the Royalty or License category, reflecting the distribution of global mRNA patent royalties to U.S.-based academic institutions and inventors (specifically, University of Pennsylvania-affiliated scientists like Drew Weissman and Andrew Cheng).

Rather than indicating a massive promotional detailing or speaker program campaign, this concentration represents legitimate intellectual property revenue sharing. For compliance officers, this highlights the necessity of segmenting Open Payments data by the nature of payment before drawing conclusions about a competitor's active field detailing or physician detailing strategies.

What did the money buy: royalty, consulting, food, or research?

Analyzing the General Payments file by the Nature of Payment classification reveals the operational mechanics of industry spending. The table below lists the total spend across all 16.13 million general payment rows by the official CMS nature-of-payment categories.

The nature-of-payment breakdown shows a highly skewed distribution:

1. Intellectual Property and KOL Strategy: Royalty/License fees and Consulting Fees combine for over 47% of all general payments ($1.85 billion). This is highly concentrated among a small number of academic inventors, university hospitals, and elite clinical advisory board members.
2. Speaker Bureaus: Compensation for services other than consulting (which includes speaker bureaus and promotional faculty fees) remains a significant promotional pillar at $751.9 million (19.2%).
3. Detailing Volume (The "Lunch" Signal): Food and Beverage accounts for $443.4 million (11.3%). While this is a smaller share of dollars, it represents the vast majority of the 16.13 million records. The typical physician detailing interaction is not a six-figure consulting arrangement, but rather a $44 food-and-beverage line item associated with an in-office educational presentation by a pharmaceutical representative.

Which drugs and physician specialties concentrated the spending?

Evaluating the Open Payments database by drug or biological name reveals the therapeutic areas receiving the highest commercial and clinical investment.

Top drugs in General Payments: device, radioligand, and biologic leaders

The General Payments file requires reporting entities to list up to three associated drugs, devices, biologicals, or medical supplies for each transaction. Our analysis of the first associated product name (excluding general category terms like "General - Therapies") reveals the top general-payment drivers:

1. Arthrex (Device/System): $69,633,079. This represents orthopedic surgical device royalties and surgeon training consulting fees, reflecting the surgical device industry's heavy reliance on clinical consultants.
2. Pluvicto (Lutetium Lu 177 vipivotide tetraxetan): $65,279,467. The high General Payments volume for Novartis’s radioligand therapy reflects significant investment in nuclear medicine specialist consulting, speaker bureaus, and regional center training.
3. Da Vinci Surgical System (Device): $50,329,561. This represents Intuitive Surgical’s extensive surgeon credentialing, proctoring, and robotic system training programs.
4. Dupixent (Dupilumab): $43,919,487. Led by Sanofi and Regeneron, this reflects the massive promotional detailing, office lunches, and speaker bureau support for Dupixent across its multiple indications (atopic dermatitis, asthma, nasal polyps, EoE, COPD).
5. Tecentriq (Atezolizumab): $43,117,918. Driven by Genentech, this oncology biologic saw significant hospital and physician education support.
6. Botox (OnabotulinumtoxinA): $33,620,509. Driven by AbbVie, this includes both aesthetic and therapeutic speaker programs and advisory board fees.

Top drugs in Research Payments: the oncology pipeline lead

In contrast to general payments, Research Payments are dominated by clinical trials for high-cost therapeutics, with oncology drugs taking a commanding lead.

1. Keytruda (Pembrolizumab): $224,042,555. Merck’s PD-1 inhibitor leads all individual products in research payments, reflecting hundreds of active investigator-initiated trials (IITs) and registrational studies.
2. Fabhalta (Iptacopan): $135,552,627. Novartis’s oral factor B inhibitor for paroxysmal nocturnal hemoglobinuria (PNH) and IgA nephropathy is backed by an intensive global clinical trial program.
3. Zejula (Niraparib): $134,430,790. GSK’s PARP inhibitor research payments support extensive clinical trials in ovarian and breast cancers.
4. Scemblix (Asciminib): $133,090,392. Novartis’s ABL1 inhibitor for chronic myeloid leukemia (CML) shows a heavy clinical research investment.
5. Krystexxa (Pegloticase): $119,117,347. Horizon/Amgen's refractory gout biologic has a single trial evaluating Krystexxa plus methotrexate that generated $118.1 million in research payments alone.

Specialty concentration: where orthopedic surgery and internal medicine lead

Our aggregation of the Covered_Recipient_Specialty_1 field in the General Payments file shows which physician specialties receive the most industry interaction:

• Orthopaedic Surgery: $332,135,135. Orthopedic surgeons represent the highest general payment specialty, driven by orthopedic device royalties (Stryker, Zimmer Biomet, DePuy, Arthrex) and surgeon consulting.
• Internal Medicine: $193,211,705. Internal medicine physicians represent the largest volume of detailing interactions, reflecting their broad prescribing base for primary care blockbusters (diabetes, cardiovascular, respiratory).
• Neurology: $102,871,441. Driven by specialty neurology drugs (multiple sclerosis, migraine preventives, epilepsy).
• Dermatology: $101,838,790. Driven by the intense biologic and JAK inhibitor competition for psoriasis and atopic dermatitis.
• Cardiovascular Disease: $85,537,990. Driven by DOACs, PCSK9 inhibitors, and heart failure therapies.
• Hematology & Oncology: $71,879,874. Reflects oncology speaker bureau programs, advisory boards, and detailing.

Where geographically did the money land, and who were the largest individual recipients?

Top recipient states: Pennsylvania's IP lead

The geographic distribution of general payments is typically proportional to population, with California, Texas, Florida, and New York leading. However, the Program Year 2025 General Payments dataset shows a major shift:

1. Pennsylvania (PA): $713,306,030. Pennsylvania leads all states by a massive margin, representing over 18% of the national General Payments total.
2. California (CA): $423,777,656.
3. New York (NY): $260,029,755.
4. Texas (TX): $241,193,869.
5. Florida (FL): $231,575,569.

Pennsylvania’s lead is entirely driven by the BioNTech mRNA patent royalty payments. Because the University of Pennsylvania holds the foundational patents licensed to BioNTech and Pfizer for their COVID-19 vaccines, the royalty payments to the university and its resident scientists are logged under Pennsylvania covered recipient addresses, artificially skewing the state-level distribution.

Top individual physician recipients in PY2025

The Open Payments dataset is a matter of public record. For Program Year 2025, the top individual physician covered recipients were led by academic inventors receiving intellectual property royalties and orthopedic surgeon consultants:

1. Andrew Cheng (Internal Medicine / PA): $55,070,157. Represents licensed patent royalties associated with mRNA vaccine technology.
2. Nitin Goyal (Orthopaedic Surgery / VA): $30,000,068. Represents orthopedic reconstructive joint device royalties and consulting fees.
3. Matthew Allaway (Urology / MD): $20,624,190. Represents urology surgical device/biopsy technology licensing and royalties.
4. Kevin Foley (Neurological Surgery / TN): $20,179,978. Represents spinal surgical device royalties and consulting.
5. Ivan Osorio (Neurology / KS): $18,183,201. Represents neurological device/neuromodulation system royalties.
6. Drew Weissman (Internal Medicine, Allergy & Immunology / PA): $12,826,686. Represents licensed patent royalties for mRNA technology.

For compliance and market access teams, these numbers must be framed neutrally. The top recipients are predominantly academic inventors receiving public record, contractually defined royalties for pioneering inventions (such as the mRNA technology that enabled rapid vaccine development) or orthopedic surgeons co-developing complex surgical hardware, rather than physicians receiving promotional detailing or speaker fees.

Compliance and commercial implications for market access

The publication of the 2025 Open Payments data carries critical compliance and commercial implications for biopharmaceutical manufacturers:

1. Detailing Audits: Market access and commercial strategy teams should use this data to audit their competitors' KOL networks. Seeing where a competitor is allocating its consulting fees or speaker bureau dollars reveals which therapeutic indications or regional health systems they are targeting.
2. Compliance Guardrails: CMS has steadily increased its auditing and enforcement of reporting errors. Under the manufacturer compliance framework, failing to report transfers of value or misclassifying payments (e.g., mislabeling a speaker fee as a consulting fee) can trigger Sunshine Act civil monetary penalties. For 2026, those inflation-adjusted penalties can reach roughly $1.44 million in aggregate annual CMPs for knowing failures (about $144,000 per unreported payment), and about $216,000 in aggregate annual CMPs for non-knowing failures.
3. Payer Inspection: Commercial payers and pharmacy benefit managers (PBMs) increasingly audit Open Payments data to identify potential provider prescribing biases. High general payment concentrations on a specific drug within a health system can trigger prior authorization (PA) audits or restrictive formulary reviews by payers.
4. Internal Linkages: These financial flows represent the provider-facing counterpart to the patient-facing support systems. While Open Payments tracks HCP-facing transfers of value, manufacturers also direct billions of dollars to patient-facing support channels, including co-pay assistance and accumulator adjustment programs. Understanding both sides of this financial coin is essential for complete market access intelligence.

Reporting thresholds: 2025 vs. 2026

CMS adjusts the reporting thresholds for manufacturers annually based on the Consumer Price Index for All Urban Consumers (CPI-U). Transactions below these thresholds do not need to be reported unless the annual aggregate transfer of value to a single covered recipient exceeds the aggregate threshold.

• Program Year 2025 Thresholds: Single payment threshold of $13.46; annual aggregate threshold of $134.54.
• Program Year 2026 Thresholds: Single payment threshold raised to $13.82; annual aggregate threshold raised to $138.13.

Commercial operations teams must adjust their CRM and expense-tracking systems (such as Veeva or Concur) to these exact thresholds to ensure accurate reporting and prevent compliance flags.

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FAQs

When was 2025 Open Payments data published and what period does it cover?

CMS published the Program Year 2025 Open Payments dataset on June 30, 2026. The data covers all financial transfers, royalties, research grants, consulting fees, food, and travel provided by applicable manufacturers and GPOs to covered recipients from January 1 through December 31, 2025.

Are Open Payments totals rising or falling compared to 2022 and 2024?

Open Payments totals are rising significantly. Total reported transfers of value reached $14.67 billion in Program Year 2025, representing a 16.5% increase compared to the $12.59 billion reported in Program Year 2022. This growth is primarily driven by a 25.3% expansion in Research Payments, which rose from $7.58 billion in 2022 to $9.50 billion in 2025.

Why is BioNTech the top general-payment company when it is not a large physician-detailing firm?

BioNTech SE leads the General Payments file with $536.4 million because the Open Payments program includes licensing and patent royalties in the general payments dataset. BioNTech’s payments are almost entirely concentrated in the "Royalty or License" category, representing mRNA patent royalty shares paid to academic institutions and inventors based in the U.S. (such as the University of Pennsylvania), rather than field force detailing or speaker bureau expenses.

Does Open Payments cover devices and medical supplies in addition to drugs?

Yes. The Physician Payments Sunshine Act applies to applicable manufacturers of any drug, device, biological, or medical supply covered under Medicare, Medicaid, or the Children's Health Insurance Program (CHIP). Orthopedic device manufacturers (such as Stryker, Zimmer Biomet, and Arthrex) and robotic surgery firms (Intuitive Surgical) represent several of the top spots in the General Payments file due to surgical consulting and design royalties.

What is the minimum payment that must be reported for program year 2025?

For Program Year 2025, individual transfers of value under $13.46 did not need to be reported, unless the total annual transfers to that specific physician, hospital, or non-physician practitioner exceeded the aggregate threshold of $134.54. For Program Year 2026, these thresholds are adjusted to $13.82 for single payments and $138.13 for the annual aggregate.

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Sources

1. Centers for Medicare & Medicaid Services (CMS). "Open Payments Program Year 2025 Dataset." Published June 30, 2026. Available at: CMS Open Payments Data
2. Centers for Medicare & Medicaid Services (CMS). "Data Collection for Open Payments Reporting Entities: CPI-U Adjusted Thresholds." Available at: CMS Reporting Thresholds
3. U.S. Department of Health and Human Services (HHS). "Physician Payments Sunshine Act; Final Rule (42 CFR Parts 402 and 403)." Federal Register. Available at: Federal Register 42 CFR
4. Centers for Medicare & Medicaid Services (CMS). "CMS Publishes Program Year 2022 Open Payments Data." GovDelivery Archive. Available at: CMS PY2022 Announcement
5. qordata. "Key Facts About the 2025 Open Payments Data." Published July 2026. Available at: qordata Open Payments Analysis
6. National Academy for State Health Policy (NASHP). "Physician Payment Transparency and State Compliance Scans." Updated December 2025. Available at: NASHP State Scans