Open Payments accuracy
Of 17 million Open Payments records published in one year, just 466 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 roughly 17 million records published in a recent program year, only 466 were formally disputed, a 0.00273% 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.
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, and estimates verification removes roughly 90% of it.