Research and general payment relationships increasingly overlap, and a growing share is with the same company. Here's what the data shows, and doesn't.
Of the 31,167 physicians who served as a Research Payment Principal Investigator (PI) in CMS Open Payments data in 2025, 25,596 also received a General Payment, consulting, speaking, or other non-research compensation, from a manufacturer that same year. That's 82.1% of research PIs, up from 79.6% in 2023.
Narrow it to the same manufacturer, and the share of research relationships that also carry a general payment from that exact company rose from 28.7% in 2023 to 31.0% in 2025. Roughly 3 in 10 industry-funded research relationships now run alongside a non-research financial relationship with the same company, and the share is climbing.
This is the closest this dataset gets to a structuring question, and it's worth being direct about what it does and doesn't show. Nothing here proves a research payment was mislabeled. What it shows is how often a research relationship and a general payment relationship exist for the same physician, and how often it's with the same company.
| Program year | Research PIs | Also received a General Payment | Overlap |
|---|---|---|---|
| 2023 | 31,544 | 25,099 | 79.6% |
| 2024 | 31,597 | 25,547 | 80.9% |
| 2025 | 31,167 | 25,596 | 82.1% |
Both lines move the same direction. The overall overlap rate and the same-payer overlap rate have both climbed in each of the three years measured.
Research Payment records missing both a ClinicalTrials.gov identifier and a study name show meaningfully higher average payment amounts in every year measured, 5.0x higher in 2023, 3.0x higher in 2025. That's a documentation-completeness pattern, not proof of anything improper. Legitimate observational and proprietary-protocol research can lack a public trial registration.
Splitting the gap out by research type sharpens it. Every non-preclinical research payment record in 2023, 2024, and 2025, essentially anything tied to a named clinical study, carries a study name on file. The gap lives entirely inside preclinical research, where undocumented payments still average roughly 2-4x more than fully documented ones each year ($29,739 vs. $7,847 in 2023; $27,382 vs. $10,138 in 2025).
CMS's own audit guidance, Open Payments: Audit Best Practices 2026, lists documentation related to General Payment records, documentation related to Research Payment records, and agreements for consulting fees, speaker or educational fees as separate categories an auditor can request.
82.1% in 2025, up from 79.6% in 2023 and 80.9% in 2024. Of the 31,167 physicians who served as a Research Payment Principal Investigator in 2025, 25,596 also received a General Payment, such as consulting, speaking, or other non-research compensation, from any manufacturer that same year.
It's the narrower share of research relationships where the Principal Investigator also received a General Payment from that exact same manufacturer, not just any manufacturer, in the same year. That share rose from 28.7% in 2023 to 31.0% in 2025, meaning roughly 3 in 10 industry-funded research relationships now run alongside a non-research financial relationship with the same company.
No. This is a monitoring indicator, not evidence that any specific payment was misclassified. A physician can legitimately run industry-funded research and also serve as a paid consultant for the same company. What it means is that a growing share of research relationships also carry a general payment stream that needs to stay documented and segregated.
Check what share of your Research Payment records are missing both a ClinicalTrials.gov identifier and a study name, then check what share of your research PIs also received a general payment from your company the same year. qordata's CMS Audit Risk Report includes the full methodology and national benchmarks, and qordata's CARE team can run this check against your own data directly.
