The Open Payments dispute deficit: why only 305 of 16 million general payments stay disputed

It is tempting to read a tiny dispute rate as a sign the data is clean. It is the opposite. It is the clearest sign that the people who could catch the errors are not looking.

One caveat makes the number a floor, not a census. The published flag shows dispute status at publication only. A dispute raised and settled before the data went public leaves no mark in the file, so more than 305 physicians may have checked. The scale does not change. The last time CMS published a full count, for program year 2016, physicians and teaching hospitals disputed 5,021 of 11.96 million records. That is 0.04 percent. Either way you count it, the review window goes almost unused.

The data is error-prone by construction

CMS published 16,131,856 general payments for program year 2025: meals, travel, small honoraria, and similar low-dollar transfers. Most are entered by field representatives into corporate expense systems and flow through to CMS with little physician-level validation. Names get misspelled, the wrong NPI gets attached, an amount gets keyed twice. These are ordinary data-entry errors at enormous scale.

The dispute process is the bottleneck

A physician who wants to correct a record has to know the record exists, register with the CMS Open Payments system, find the entry during a limited annual review window, initiate a dispute, and get the reporting company to correct it before the deadline. Most physicians never learn a given payment was reported in their name, and the ones who do rarely have the time to run the process. The result is an administrative dispute deficit: the records publish, unverified, and stay published.

Why it matters to the company, not just the physician

Every unverified record is a record the Department of Justice can later mine against Medicare claims, and every inaccurate one is a distinct penalty exposure. A dispute rate near zero does not lower that risk. It just means no one corrected the errors before they became a permanent, public federal record.

Closing the gap

The fix is to move verification before submission instead of after. If the physician confirms or disputes each payment in one place before it is filed, the errors get caught at the source, the dispute deficit stops mattering, and what publishes is what both sides agree is true.