Open Payments accuracy
Of the 16,131,856 general payments CMS published for program year 2025, just 305 were still disputed when the data went public. 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 to $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 to $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 to $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 inflation-adjusted maximum near $1.66 million a year.
Of the 16,131,856 general payments published for program year 2025, only 305 were still disputed when the data went public. Disputes settled before publication are not flagged, so 305 is a floor on how many physicians checked, not a census. Either way, almost no one is looking.
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.
A COI disclosure software checklist is a list of requirements a conflict-of-interest office can put to any vendor. This one is vendor-neutral and printable. It treats reconciliation against the federal Open Payments record, by NPI and program year, as a minimum requirement.
Reconciling COI disclosures against Open Payments means matching each person on your roster to the federal record by NPI, comparing what they disclosed with what companies reported for the same program year, and resolving each difference with that person on a dated record.
The 2027 Open Payments calendar is expected to follow CMS's standing cycle: a data refresh in January, company submissions in February and March, a review and dispute window from April 1 to May 15, and publication of program year 2026 by June 30.
The PHS $5,000 threshold and the Open Payments reporting threshold answer different questions. PHS asks an investigator whether interests in one entity exceed $5,000 over twelve months. Open Payments asks a company to report most payments above a small floor CMS adjusts each year.