Concentration is flat and not the story. A small, specialty-concentrated group of physicians and hospitals drives the spikes that matter.
Across the full 2023-2025 CMS Open Payments dataset, the top 1% of paid physicians receive roughly two-thirds of all General Payment dollars, and that share barely moves year to year. That's not the story. The story is a much smaller group of physicians and hospitals whose payments jump suddenly, and where those jumps concentrate.
Using a conservative threshold, a prior-year payment of at least $1,000 with a current-year increase of at least 200% and at least $5,000 in absolute dollars, qordata's analysis of the full three-year Open Payments files found 5,544 physicians flagged in 2024 and 6,197 in 2025. That's about 3.7% of eligible physicians each year, against a typical physician's actual median year-over-year change of negative 14.3%.
High concentration in Open Payments data is easy to mistake for a red flag. It isn't one on its own. The top 1% of paid physicians consistently receive roughly two-thirds of all General Payment dollars across 2023, 2024, and 2025, a share that barely moves. That pattern is driven by royalty and licensing payments to a small number of physician-inventors, people who hold patents on devices or techniques and are compensated accordingly. It's a structural feature of how the industry pays a handful of specialists, not evidence of anything improper.
The signal worth watching is different: sudden, large, year-over-year increases at the individual or institution level.
It isn't spread evenly across specialties. In the 2024 cohort, orthopaedic surgery alone accounts for $75.8 million of the $256.4 million in flagged increases, 29.6% of the total, across 369 physicians. That's more than seven times the next largest specialty, internal medicine, at $10.8 million.
Institution-level spikes follow the same shape, and they're fully public and directly citable in CMS's own data, not an inference from aggregated figures.
Wadley Regional Medical Center rose 802% from 2023 to 2024. Waterbury Hospital rose from $3,236 to $1,956,762 between 2024 and 2025, a 604% increase spread across 19 different reporting entities and 55 separate payments. Christ Hospital rose 378% over the same period, across 12 payers and 134 payments. In every case, the shape is the same: a sudden, large, multi-payer increase, not one outsized transaction that would be easy to explain away.
CMS's own audit guidance, Open Payments: Audit Best Practices 2026, names entity size as one of the factors behind issue-based selection. A sudden, large, multi-payer increase to a specific physician or hospital is precisely the shape of pattern a compliance officer should be able to explain before an auditor asks about it.
Not by itself. The top 1% of paid physicians receive roughly two-thirds of all General Payment dollars in every year from 2023 to 2025, and that share is flat. It's driven by royalty and licensing payments to a small number of physician-inventors, a structural feature of the data, not a warning sign on its own.
qordata's analysis used a conservative bar: a prior-year payment of at least $1,000, a current-year increase of at least 200%, and at least $5,000 in absolute dollar growth. Against a typical physician's actual median year-over-year change of negative 14.3%, that flagged 5,544 physicians in 2024 and 6,197 in 2025.
Orthopaedic surgery. In the 2024 cohort, 369 orthopaedic surgeons alone accounted for $75.8 million of the $256.4 million in flagged increases, 29.6% of the total and more than seven times the next largest specialty.
Run every HCP and HCO in your reporting entity against the same criteria: a 200%+ year-over-year increase with at least $5,000 in absolute growth. Flag anyone who clears that bar for a documented explanation, especially if they cluster in one specialty. qordata's CMS Audit Risk Report includes the full methodology, and qordata's CARE team can run this benchmark against your own data directly.
