Open Payments accuracy
Of the 16,131,856 general payments CMS published for program year 2025, just 305 were formally disputed. That is not clean data. It is a dispute deficit, and the errors publish anyway, into the database the Department of Justice mines.
Source: CMS Open Payments, PY2025 aggregates.
Three escalating layers
Each inaccurate record is a distinct violation: $1,443–$14,432 per record (negligent), up to $144,329 (knowing), with a combined statutory maximum near $1.66M a year. CMS treats an inaccurate record the same as an unreported one.
The Department of Justice mines Open Payments against Medicare claims to build kickback and False Claims Act cases. The largest settlements in this area are physician-payment cases carrying treble damages.
Every correction costs $750–$1,500 in loaded labor, and an inaccurate entry can trigger a physician's hospital conflict-of-interest audit and cost a future engagement. Programs run $2–5M a year carrying this.
Penalty figures are public statutory maximums. Cost ranges are illustrative estimates from published compliance research, not legal, tax, or compliance advice.
The fix
You would not ship code without a review. You should not report a physician payment without the physician confirming it. PayClear gives each physician one ledger of every industry payment they receive and a channel to confirm or dispute each one, before it becomes a public, legally binding record. You report clean, audit-ready data.
Go deeper
An inaccurate Open Payments record is treated the same as a failure to report. Civil monetary penalties run $1,443–$14,432 per record for negligent errors and up to $144,329 for knowing ones, with a combined statutory maximum near $1.66 million a year.
Of the 16,131,856 general payments published for program year 2025, only 305 were formally disputed, a 0.001891% rate. That is not evidence of clean data. It is evidence that almost no one checks.
You can dispute an incorrect Open Payments record, but you have to register with CMS, find the record during a limited annual window, and get the reporting company to correct it before the deadline. Here is the process and why so few complete it.
The Department of Justice mines Open Payments against Medicare claims to build kickback and False Claims Act cases. The largest settlements in this area are physician-payment cases carrying treble damages.
A company reports a payment to CMS under the Sunshine Act. The physician attests to it under the hospital's conflict-of-interest policy. The hospital certifies the program that collects those attestations. Three duties describe the same dollar, none of them reconcile before publication, and the first place they meet is the public record.
CMS publishes every industry payment to your medical staff by June 30 each year and refreshes the data again in January. A workable monitoring program follows that calendar: reconcile attestations against the public record, sample the high-exposure roles, and route errors into the dispute window before they publish.
Companies report what their systems attribute to you: a badge scan at a conference booth, your share of a group dinner, travel a third party booked in your name, research money attributed to you as principal investigator. A record like that can be disputed, but only on the program calendar.
Beyond penalties, inaccurate records carry remediation labor, KOL relationship friction, and audit exposure. A conservative model puts the annual carrying cost of a large manufacturer near $798,000, on assumptions this page states in full.