Track and analyze your Sunshine Act Open Payments spending across consulting, speaking, meals, travel, education, and research categories. Monitor HCP reporting thresholds, identify compliance risks, and ensure regulatory transparency.
The Physician Payments Sunshine Act requires pharmaceutical and medical device companies to report payments and transfers of value to physicians and teaching hospitals to CMS Open Payments. This tracker helps you analyze spending patterns, identify HCPs above reporting thresholds, and assess compliance risk.
Input annual spend and HCP count for each category to analyze compliance exposure and reporting requirements.
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The Physician Payments Sunshine Act, enacted as part of the Affordable Care Act in 2010, requires applicable manufacturers of drugs, devices, biologicals, and medical supplies to report payments and other transfers of value to physicians and teaching hospitals to the Centers for Medicare & Medicaid Services (CMS). The data is published publicly in the Open Payments database, creating unprecedented transparency in the relationships between industry and healthcare providers.
Consulting Fees
Payments for consulting services, advisory board participation, and expert input. These are typically the highest per-HCP payments and receive the most scrutiny from compliance teams and the public. Average consulting fees range from $2,000 to $5,000 per engagement.
Speaking / Honoraria
Speaker program honoraria for peer-to-peer educational events. These are reported as compensation for services and must include the event details, topic, and compensation amount. Typical honoraria range from $1,500 to $3,500 per program.
Meals and Food
The most common transfer of value by volume, meals must be reported when the per-meal value exceeds $10. While individually small, meals often account for the highest number of individual transactions. Companies should track all meals to ensure accurate annual aggregation per HCP.
Travel and Lodging
Travel costs including airfare, hotel, ground transportation, and related expenses for HCPs attending company-sponsored events, advisory boards, or speaker programs. Each component must be reported separately in Open Payments.
Education and CME
Continuing medical education support, including accredited CME programs and educational materials. While some CME payments are reported indirectly (through accredited providers), direct sponsorship must be tracked and reported.
Research Payments
Research funding, clinical trial payments, and research-related transfers of value. These are typically the largest aggregate payments and are reported separately from general payments in the Open Payments database. Research payments often involve institutional rather than individual HCP payments.
Any transfer of value of $10 or more must be reported to CMS. Payments under $10 are not reportable individually but must be tracked for annual aggregation; if cumulative payments to a single HCP exceed $100 in a year, all payments including those under $10 become reportable. Companies must submit data annually, with a 30-day review and dispute period for physicians. Penalties for non-compliance can reach $1,000,000 per year for knowing failures to report.
What triggers a reporting requirement?
Any transfer of value to a covered recipient (physician, teaching hospital, or other applicable entity) of $10 or more in a single interaction, or cumulative payments of $100 or more in a calendar year. Transfers include cash, cash equivalents, in-kind items, services, and other items of value.
What is the compliance risk score?
The compliance risk score (1-10) evaluates your spend patterns based on average spend per HCP, concentration of spending in high-scrutiny categories, and the percentage of HCPs above reporting thresholds. Higher scores indicate greater compliance exposure that may warrant additional monitoring and internal review.
How is the compliance risk score calculated?
The risk score considers: average spend per HCP across categories, the proportion of HCPs receiving high-value payments (above $5,000 per category), concentration in consulting and speaking categories (higher public scrutiny), and the ratio of reporting-eligible HCPs to total HCPs engaged.
Are nurse practitioners and physician assistants covered?
Yes. Since 2021, the Sunshine Act was expanded to include nurse practitioners, physician assistants, and other mid-level prescribers as covered recipients. Transfers of value to these providers must now be reported to Open Payments.
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