On June 30, 2026, CMS published the Program Year 2025 Open Payments data, the annual disclosure of payments and transfers of value that drug and medical device manufacturers made to physicians, teaching hospitals, and other covered recipients throughout 2025. We pulled the full General Payments file, more than 16 million individual records, and analyzed it end to end. Here is what stood out, and what it means for compliance programs heading into next year's reporting cycle.
General Payments, the category covering meals, travel, consulting, speaking fees, royalties, gifts, and similar transfers not tied to a research agreement, totaled 16.13 million records worth $3.92 billion from 1,854 reporting manufacturers and GPOs in Program Year 2025.
Note: this figure covers General Payments only. CMS publishes Research Payments and Ownership/Investment Interests as separate files, and those categories add substantially more to the government's own combined "total Open Payments" figure (for Program Year 2024, CMS cited $13.18 billion across all three categories combined). The General Payments file is the category most relevant to day-to-day HCP engagement compliance, which is why we focused our analysis there.
Royalty or License payments were the single largest payment category by dollar value, $1.20 billion (30.7% of all General Payments dollars), but came from only 15,496 records. That is an average of about $77,700 per record, and reflects a small number of very large licensing arrangements rather than routine HCP engagement.
By contrast, Food and Beverage was the most common transaction by far: 14.76 million records (91.5% of all records) but only $443 million (11.3% of dollars). The two categories tell opposite stories; one is high dollar value concentrated in very few transactions, the other is high volume spread across nearly every record in the file.
Covered Recipient Physicians accounted for $2.62 billion across 10.13 million records, about two-thirds of all General Payments dollars. Teaching hospitals received $1.03 billion from just 35,569 records, an average of roughly $28,900 per record, by far the highest per-record value of any recipient type. Non-physician practitioners (nurse practitioners, physician assistants, and similar roles, added to Open Payments reporting under the 21st Century Cures Act) accounted for $270.5 million across 5.97 million records.
Among physician specialties, Orthopaedic Surgery led by dollar value at $332.1 million, followed by Internal Medicine ($193.2M), Neurology ($102.9M), Dermatology ($101.8M), and Neurological Surgery ($94.2M). In total, 391 distinct specialty combinations appear in the data.
1,854 distinct manufacturers and group purchasing organizations submitted records in Program Year 2025. The top of the list, however, is shaped by a few large one-time items rather than broad-based spending:
The gap between BioNTech's record count (147) and its dollar total ($536M) versus AbbVie's broad footprint (1.68M records, $201.5M) illustrates why manufacturer rankings by dollar value alone can be misleading without also looking at record count and payment nature.
Pennsylvania recipients received the highest total General Payments of any state, $713.3 million, ahead of California ($423.8M), New York ($260.0M), Texas ($241.2M), and Florida ($231.6M). Payments were reported across 60 distinct state/territory codes.
A few figures stood out from a monitoring and audit-readiness perspective:
Only 305 of 16.13 million records (0.0019%) were flagged as disputed in this publication, a very low rate, though a low dispute rate is not the same as a low-risk data set. Most compliance exposure surfaces well before a formal CMS dispute is ever filed. And 93.6% of records were tied to a specific covered drug, biologic, or device, underscoring how closely payment activity tracks specific products, exactly the kind of product-level linkage that internal monitoring should be validating continuously, not just once a year at submission time.
86.2% of all records were in-kind items and services, while representing only 17.2% of total dollars, a reminder that expense monitoring programs built to catch dollar-value outliers can still miss volume-based policy violations hiding in high-frequency, low-dollar transactions.
The scale of this file, over 16 million records from 1,854 manufacturers, is a reminder of why manual, sample-based expense review leaves so much unexamined. qordata's Expense Monitoring & Auditing (EMA) solution is built to analyze 100% of expense data rather than a sample, and Compliance Central unifies transparency reporting, monitoring, and HCP engagement tracking so patterns like the ones above surface long before the next Open Payments publication, not after.
Methodology: Figures are computed directly from CMS's Program Year 2025 General Payments detail file (OP_DTL_GNRL_PGYR2025_P06302026), published June 30, 2026, and reflect 16,131,854 of 16,131,942 total data rows (99.9995%); a small number of rows were excluded due to CSV formatting edge cases and the omission is immaterial to the totals above. Figures reflect General Payments only and exclude CMS's separate Research Payments and Ownership/Investment Interest files.