Methodology & Data Sources
Primary Data Source
All data comes from the CMS Open Payments dataset, published by the Centers for Medicare & Medicaid Services under the Physician Payments Sunshine Act (part of the Affordable Care Act). Open Payments requires pharmaceutical and medical device companies to report all payments and transfers of value made to physicians and teaching hospitals.
CMS makes the full dataset publicly available at openpaymentsdata.cms.gov. PlainPharmaWatch uses Program Year 2024 data.
Processing Pipeline
We download the annual CMS Open Payments dataset, which contains individual payment records for each transaction between pharmaceutical companies and healthcare providers. The raw dataset contains millions of individual transaction records. Our ETL pipeline processes this data through several stages:
- Aggregates individual transaction records by company (AMGPO) to compute total payments, transaction counts, and payment type breakdowns across all 16 general payment categories
- Aggregates by state to produce geographic payment summaries showing how pharmaceutical spending is distributed across the United States
- Identifies the top 10,000 physician and teaching hospital recipients by total payment amount, providing detailed payment breakdowns for each
- Computes company-to-recipient payment links for the highest-paid relationships, showing which companies pay which physicians the most
- Preserves AMGPO names and NPI identifiers as reported by companies to CMS, maintaining traceability to the original government data
No payment data is modified, aggregated across years, or editorially interpreted. All amounts reflect what companies reported to CMS for the specified program year.
Payment Categories Covered
CMS Open Payments tracks 16 categories of general payments, including: consulting fees, food and beverage, education, travel and lodging, gifts, speaking fees, research, royalties, grant funding, entertainment, and others. Research payments (clinical trial support) and ownership interest payments are reported separately from general payments.
Update Schedule
CMS publishes Open Payments data annually, typically releasing the previous program year's data approximately 12 months after the reporting period ends. We update our database when each new annual release becomes available. Between releases, the database reflects the most recently published program year. Historical program year data is not retroactively modified by CMS except through the dispute resolution process.
Data Accuracy and Context
All payment data originates from reports submitted by pharmaceutical and medical device companies to CMS as required by law. CMS performs basic validation but does not independently audit every transaction. Recipients (physicians and teaching hospitals) have a review and dispute window before data is published. Payments that are successfully disputed are either corrected or removed from the public dataset. Our database preserves the data exactly as published by CMS after the dispute resolution period.
Limitations
- We show the top 10,000 recipients by total payments. Individual records for smaller recipients are included in aggregate totals but are not listed separately.
- Payment amounts reflect what companies reported to CMS. CMS provides a dispute resolution process for recipients who believe data is inaccurate.
- Receiving payments from pharmaceutical companies is legal and common practice. Payments do not imply wrongdoing or conflicts of interest in any specific case.
- Program Year 2024 data reflects the most recently published CMS release. CMS publishes data with an approximate 12-month lag.
- AMGPO (Applicable Manufacturer or Group Purchasing Organization) names may vary across records for the same corporate entity due to subsidiaries and naming inconsistencies.
- Research payments (clinical trial support) are reported separately from general payments and may not appear in all views.
Regulatory Standards & YMYL Context
PlainPharmaWatch operates in a Your-Money-or-Your-Life domain (healthcare financial transparency). Although we do not regulate the pharmaceutical industry directly, our methodology aligns with the disclosure framework established by the U.S. Food and Drug Administration (FDA) and complements pharmaceutical-quality oversight performed by United States Pharmacopeia (USP) compendial standards. Specifically:
- FDA's Physician Payments Sunshine Act enforcement (42 CFR Parts 402 and 403) is the statutory basis for the CMS Open Payments dataset PlainPharmaWatch ingests; FDA-approved drug and device manufacturers are the reporting entities listed in our companies table.
- USP compendial standards (USP-NF) govern the identity, strength, quality, and purity of drugs marketed in the United States. Many of the manufacturers that appear in our payment totals are also USP-listed entities — readers using this dataset for due-diligence should cross-reference USP and FDA orange-book records for any individual product or sponsor.
- This methodology page makes no clinical claims. For drug safety questions, consult FDA's MedWatch program; for compendial drug-quality questions, consult USP directly.
Disclaimer
PlainPharmaWatch is not affiliated with CMS or any federal agency. This site presents publicly available government data for informational purposes only. We do not make medical recommendations and presenting payment data does not imply any judgment about the propriety of reported payments.