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Open Payments accuracy

The PHS $5,000 SFI threshold vs Open Payments reporting thresholds

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.

Published 2026-10-18. Last checked against its sources 2026-10-18.

Two federal rules describe the same relationships from opposite ends. The PHS rule (42 CFR Part 50, Subpart F) asks a researcher what they hold. Open Payments (42 CFR Part 403, Subpart I) asks a company what it paid. Their thresholds differ by design, which is why the two records rarely line up exactly and why each is useful as a check on the other.

Side by side

Who discloses or reports
PHS (research)
The investigator discloses to their institution.
Open Payments
The company (a drug, device, biological or medical supply maker, or a group purchasing organization) reports to CMS.
Whose interests count
PHS (research)
The investigator's, plus their spouse's and dependent children's.
Open Payments
Payments to the covered recipient. Ownership interests also count when held by an immediate family member.
Who is covered
PHS (research)
Anyone responsible for the design, conduct or reporting of PHS-funded research, whatever their title.
Open Payments
Physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, certified nurse-midwives, and teaching hospitals.
The threshold
PHS (research)
For a publicly traded entity, more than $5,000 when remuneration over the prior twelve months and equity held are added together. For a non-publicly traded entity, remuneration over $5,000 in the prior twelve months, or any equity at all. Income from intellectual property on receipt.
Open Payments
Most payments, subject to a list of exclusions in the rule. Payments under $10 were excluded in 2013 unless they added up to more than $100 in the year, and CMS adjusts both amounts each year for inflation.
Travel
PHS (research)
Sponsored or reimbursed travel is disclosed whatever the amount, with some public and academic sponsors excepted.
Open Payments
Reported as travel and lodging, with its value.
Period
PHS (research)
The twelve months before the disclosure, updated within 30 days of a new interest and at least annually during an award.
Open Payments
A calendar year, reported once a year.
What becomes public
PHS (research)
Interests of senior and key personnel that the institution finds are a financial conflict, on a website or within five business days of a request.
Open Payments
The published record, by name, on or by June 30. Some research payments are held back until FDA approval or clearance, or four years after payment, whichever comes first.

Sources: 42 CFR 50.603, 50.604 and 50.605; 42 CFR 403.902, 403.904(h)(2), 403.906 and 403.910. NIH keeps its own guidance on the research rule at grants.nih.gov.

What the PHS rule leaves out

The research rule excludes salary and other pay from the investigator's own institution, income from mutual funds and retirement accounts the investigator does not direct, and pay for seminars, lectures, teaching, advisory committees or review panels sponsored by a government agency, a university, an academic teaching hospital, or a research institute affiliated with a university (42 CFR 50.603). None of those come from a company that reports to Open Payments either, so they rarely cause a difference.

Where the two will differ

  • A meal or a small consulting payment appears in Open Payments well below $5,000. It may matter to your institutional COI policy even though it is not a significant financial interest under PHS.
  • Equity in a private startup is a significant financial interest at any value. It appears in Open Payments only if the startup is a company Open Payments covers.
  • A spouse's consulting income counts toward PHS. Open Payments reports payments to the covered recipient, not to their family, apart from ownership interests.
  • PHS looks back twelve months from the date of disclosure. Open Payments is a calendar year. The same payment can fall in one period and not the other.

How to use the federal record well

Treat Open Payments as a cross-check, not the standard. Match investigators to it by NPI, compare what it shows with their disclosures, and ask about what does not line up. A payment on the federal record is a reason for a conversation, not a determination. The step-by-step method is on how to reconcile COI disclosures against Open Payments, and the dates are on the 2027 calendar. CMS lists the current program dates at cms.gov. If you are choosing software to handle both rules, the COI software checklist lists what to require. To see what the public record holds for a hospital's medical staff, look it up in the hospital directory.

This is general information, not legal or compliance advice. It describes the federal rules and the reporting system generally, not any specific organization. Check the current rule text and CMS dates at the linked sources before relying on them.

Figures verified 2026-10-18. Source: 42 CFR 50.603, 50.604 and 50.605 (eCFR); 42 CFR 403.902, 403.904(h), 403.906 and 403.910 (eCFR).

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The three dutiesMonitoring Open PaymentsCOI software checklistReconciling disclosuresThe 2027 calendar