In This Analysis
CMS Open Payments publishes two structurally different datasets under one program name, and most compliance content treats them as one story. They aren't. General Payments, $10.68 billion across 46.4 million transfers from 2023 to 2025, are individually small, flow mostly to physicians, and cover consulting, meals, speaking, and travel. Research Payments, $27.08 billion across 2.84 million transfers over the same period, are individually large, flow overwhelmingly to institutions, and follow research agreements and protocols.
Read together, the three-year trend in both datasets points to where scrutiny is most likely increasing, not because either report says so directly, but because both show the same underlying shape: dollars concentrating faster in specific categories, specific institutions, and specific manufacturer strategies than the topline growth numbers suggest.
For the audit process itself, legal authority, and response timelines, see qordata's CMS Open Payments Audit: Resources & FAQs. This analysis focuses on where the underlying data is moving, and why that movement matters for where scrutiny concentrates next.
Neither dataset is finalized for 2025; both are attested through spring 2026 and treated as provisional in this analysis, consistent with CMS's own publication timeline. Year-over-year comparisons into 2025 should be read with that caveat. None of the findings below establish wrongdoing. Open Payments data shows a transfer of value; it doesn't show intent, fair market value, or whether a bona fide arrangement sits behind any given number. What it shows, reliably, is where the underlying activity is moving fastest, and fast movement is what a review process is built to notice first.
General Payments: The Categories Outpacing the Market
Total General Payment spend grew 14.6% from $3.328 billion (2023) to $3.924 billion (2025), still preliminary for the most recent year. That aggregate number hides real divergence underneath it.
Speaker and faculty compensation reached $751.9 million in 2025, an 11.5% three-year CAGR and the largest promotional category after royalties. Consulting fees grew faster still on a relative basis: a 10.4% CAGR that accelerated to 13.1% in the most recent year alone. Food and beverage grew more slowly, 8.2% CAGR, but on ever-higher transaction counts, meaning the audit exposure in that category is spreading across more individual records, not concentrating in fewer, larger ones.
Two categories moved in the opposite direction entirely: entertainment fell 30.1% and gifts fell 6.5% over the same period, consistent with maturing company controls in the categories with the longest, most visible enforcement history. The categories growing fastest are, almost by definition, the ones controls haven't caught up to yet.
Research Payments: Where Institutional Money Concentrates
Research Payments concentrate differently than General Payments, but not less. The top 1% of research recipients received about 49% of all research dollars, and the top 10% received about 85%, spread across a recipient base of academic medical centers, cancer centers, and contract research organizations rather than individual physicians. About 99% of research dollars go to institutions; only around 1%, roughly $62.5 million in 2025, goes directly to individual physicians.
The individual clinicians most associated with this spend appear as principal investigators, who oversee but don't personally receive the funds their name is attached to. 6,130 PIs were associated with $100,000 or more in research value in all three years, a stable, recurring population concentrated in oncology, hematology, and neuro-oncology at major cancer centers. Those PI totals are an influence and oversight signal, not a compensation figure, and treating them as personal payment is one of the more common misreadings of this dataset.
The recipient list at the top of that concentration curve is dominated by a familiar set of names: MD Anderson Cancer Center led all recipients at roughly $844 million over three years, followed by the National Institutes of Health at roughly $367 million and Memorial Sloan Kettering at roughly $329 million, alongside commercial trial networks such as Velocity Clinical Research. Institutional totals at that scale deserve the same certification rigor as an individual physician's disclosure, not less, simply because the recipient is an organization rather than a person.
Manufacturer Strategy Is Diverging Fast
The clearest early-warning signal in the Research Payments data isn't a total. It's the spread between manufacturers moving in opposite directions.
Moderna's research spend fell 55%, from $741 million to $334 million, as COVID-era programs wound down. Amgen's rose 235%, from $174 million to $585 million, over the identical period. Eli Lilly led all manufacturers in three-year research spend at $2.04 billion. A swing of that size in either direction is a signal that new-program controls need to keep pace with the investment, not lag behind it. A manufacturer rapidly expanding into new therapeutic areas is, by definition, standing up new investigator relationships and new institutional agreements faster than its existing governance processes were built to handle.
Geography Tells Two Different Stories
General Payments and Research Payments don't even concentrate in the same states. General Payments lead with California ($381.0 million in 2025, up 23.4%), New York ($243.2 million, up 21.8%), and Texas. Research Payments lead with Texas ($1.18 billion) and Florida ($1.16 billion), followed by California, reflecting the location of cancer centers, academic hospitals, and contract research organizations rather than physician-engagement activity. Arizona's research spend jumped 57% in 2025 on a single large neuro-oncology award, the kind of single-award swing worth footnoting internally before it reads as an unexplained anomaly to anyone reviewing the public data.
A compliance program that built its General Payments risk geography around California and New York cannot assume the same map applies to its research programs. The two datasets require separate geographic risk views, tracked in parallel. Pennsylvania is a useful example of why: it was the fastest-growing large state in General Payments in 2025, up 41.0% year over year, a swing that would be easy to miss if a monitoring dashboard only refreshed its top-state list annually rather than continuously.
North Carolina's Research Triangle tells a parallel story on the research side: the state's research spend grew at roughly a 15% CAGR over the same period, tracking the region's density of contract research organizations and academic trial infrastructure. State-level transparency and gift-ban statutes, layered on top of the federal Sunshine Act calendar, mean a spend surge in a state with its own disclosure threshold is a compliance-calendar event in its own right, not just a sales or research-investment trend to note in passing.
What the Combined Picture Means for Monitoring Priorities
Three things are true at once, and a monitoring program that only tracks one of them is reading half the picture. Category mix in General Payments is shifting toward higher-value, service-based arrangements faster than total spend is growing. Research Payments are concentrating in a durable population of institutions and principal investigators that deserves continuous, not annual, conflict-of-interest review. And manufacturer-level strategy shifts, in either program, are themselves a leading indicator of where new governance gaps are most likely to open up.
Compliance Central tracks category mix and concentration signals across both General and Research Payments in one view rather than two separate spreadsheets. EngageAgent embeds fair-market-value and policy checks directly into the HCP and investigator engagement workflow, so the principal-investigator relationships driving Research Payments concentration carry current documentation before a conflict-of-interest question is ever asked.
