A gastroenterologist we work with learned in 2024 that the public Open Payments website listed about $9,000 in consulting fees paid to him by a device company he had never worked with. A hospital credentialing committee had found it. It took him three weeks to trace the record to another physician with the same last name and a similar first name in a different state, and by then the data was already published and had been for a year. The record was corrected in the next cycle. The conversation with the credentialing committee had already happened.
Open Payments is the federal program, created by the Physician Payments Sunshine Act provision of the Affordable Care Act, under which drug and medical device manufacturers and group purchasing organizations report payments and transfers of value they make to physicians, certain other clinicians and teaching hospitals. CMS publishes the data every June. Between the manufacturers' submission and the publication there is a window in which the clinicians named in the records can see them and dispute the ones that are wrong. For program year 2025 that window, the Open Payments review and dispute period, runs from April 1 to May 15, 2026, with a correction period for reporting entities from May 16 to May 30 and publication of the data on or before June 30, 2026.
Most physicians never look. This article explains what the records contain, why they are often wrong, how to register and review, how to dispute, and the practice-level policy that makes the process quick every spring.
Key takeaways
- Program year 2025 records can be reviewed and disputed from April 1 through May 15, 2026; anything disputed after that will not be corrected before the June 30 publication.
- Covered recipients include physicians and, since program year 2021, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists and certified nurse midwives.
- The records are compiled by the companies, not by you, and misattribution, wrong values and meals you never ate are common errors.
- CMS does not mediate disputes; the reporting entity must agree to change the record, so document your position.
- Employers, hospitals, payers, journalists, patients and federal investigators all read this data, which is why an inaccurate record is worth an hour of your time.
What is in an Open Payments record
Reporting entities submit three kinds of records. General payments cover anything of value that is not research: consulting fees, speaking honoraria, travel and lodging, meals, education, gifts, grants, royalties and the like, each tagged with a nature of payment category and often with the related drug or device. Research payments cover payments connected to a research study. Ownership and investment interests cover physician ownership in a reporting company. Small items below an annually adjusted threshold are excluded unless the total from one company for the year exceeds an aggregate cap, so a single catered lunch may or may not appear depending on its value and the year's thresholds.
Each record names the covered recipient by name, NPI, specialty and address, the company, the amount, the date, the form and nature of the payment, and any associated product. The company attributes the record to a clinician based on its own records: the sign-in sheet at a lunch, the contract for a talk, the name on an expense report. There is no step in which the company confirms with you that the record is correct before it goes to CMS. The review period is that step, and you are the only person who will take it.
Why the records are wrong more often than you would think
In our experience the errors fall into four groups. Misattribution to the wrong clinician, usually a name match without an NPI match, as in the gastroenterologist's case; this is most common for physicians with common surnames. Meals recorded for everyone on a sign-in sheet or in a practice roster regardless of who attended or ate, so a physician who was on vacation appears to have received a lunch. Values that are wrong, for example a per-head meal cost calculated from the whole invoice divided by the roster rather than by attendees, or travel booked but cancelled. And payments correctly made but miscategorized, such as a legitimate research payment reported as a general consulting fee, which reads very differently to anyone looking.
None of these is fraud, and most companies correct them readily when asked. But the data is public for years, is searchable by name, and is used by people making judgments: hospital credentialing committees, health plan network teams, medical boards, prospective employers, journalists, patients, and federal investigators, who have used Open Payments data in anti-kickback cases. A record that shows $9,000 in consulting from a company whose devices you implant invites questions you should at least be able to answer.
| Date in 2026 | What happens | What the clinician should do |
|---|---|---|
| February 1 to March 31 | Reporting entities submit program year 2025 records to CMS | Nothing yet; check that your Open Payments registration is active |
| April 1 | Review and dispute period opens | Log in, review every record, affirm or dispute |
| May 15 | Review and dispute period closes for pre-publication changes | All disputes intended to affect the June publication must be initiated by this date |
| May 16 to May 30 | Correction period: reporting entities resolve disputes and correct records | Respond to any company that contacts you; confirm corrections |
| On or before June 30 | CMS publishes program year 2025 data and refreshes prior years | Check the public record; unresolved disputes are published flagged as disputed |
| After June 30 | Disputes can still be filed; corrections appear in the next refresh | Continue to dispute errors; they will show as disputed until resolved |
How to register for the Open Payments review and dispute period
Registration is a two-part process. First, the clinician creates an account in the CMS Identity Management system (the same credential system used for other CMS portals) and verifies their identity. Second, the clinician registers in the Open Payments system, which requires the NPI, state license information and other identifiers, and takes an hour the first time. CMS allows a clinician to nominate an authorized representative, such as a practice compliance officer, to review and dispute on their behalf; the representative needs their own account and the clinician's nomination. Registration done before the window opens means the window can be used for reviewing, not for account setup.
Once logged in during the window, the clinician sees every record attributed to them for program year 2025 and any prior-year records that companies have updated. For each record there are three choices: affirm it, dispute it, or leave it without action, which CMS treats as neither. To dispute, the clinician selects the record and enters a reason in plain language: "I did not attend this event," "amount is incorrect, contract was for $1,500," "this payment was to a different physician; I have never worked with this company." The system notifies the company. The company can resolve the dispute by correcting or deleting the record, or it can stand by the record, in which case CMS publishes it marked as disputed. CMS does not decide who is right.
Keep your own evidence. A calendar showing you were elsewhere, a contract showing the actual fee, an email declining an invitation: these settle most disputes in one exchange with the company's compliance contact. Save the dispute confirmation and any correspondence in the practice's compliance file.
A practice policy that makes next April easy
Two things at the practice level shorten the review every year. The first is a log. Ask each clinician to record industry interactions as they happen: the company, the date, what was received, the approximate value, and whether they attended. A shared spreadsheet or a note in the compliance folder is enough. In April the review becomes a comparison of two lists rather than an exercise in memory, and disputes can cite the log.
The second is a written policy on what the practice accepts from industry. Many practices now decline meals and gifts entirely, accept only educational materials, and require any consulting or speaking arrangement to be in writing at fair market value with the compliance officer's knowledge. The federal Anti-Kickback Statute and the Stark law govern financial relationships with companies whose products you prescribe or order, and several states add their own gift restrictions and reporting; the policy is where you set the practice's line, and counsel should review it. A practice whose policy is "no meals, written contracts only" tends to have a very short Open Payments list, and every item on it has a document behind it.
Assign the compliance officer to send the reminder on April 1, confirm each clinician has reviewed by May 1, and check the published data in July. Practices that have us run a compliance calendar as part of an RCM audit engagement get this as a standing item; it is also on the annual review checklist for practices in our PCMH annual review work, since NCQA looks for a functioning compliance process.
Questions we hear
We are a small practice and nobody takes industry money. Do we still need to review?
Yes, once, because the point is what companies reported, not what you accepted. A physician who takes nothing can still be misattributed a payment, and the only way to know is to look. If the record is empty, the review takes five minutes and you have documented that you checked.
A drug representative brought lunch for the staff. Is that reported against the physician?
Often, yes. Companies commonly allocate the cost of a lunch across the clinicians who signed in or who were listed as present, and the per-clinician value may exceed the reporting threshold. Staff who are not covered recipients (medical assistants, front desk, most nurses) are not reported, so the whole cost can land on the two or three physicians and NPs in the room. If you did not eat, dispute it; better, decide as a practice whether you want these lunches at all.
Does disputing a record remove it from the public site?
Only if the company agrees and corrects or deletes it during the correction period. If the company stands by the record, it is published with a "disputed" flag, which at least tells anyone reading it that you contest it. Disputes filed after May 15 are processed but the change appears in a later data refresh, so the timing matters.
What to do this week
- Have every physician, PA and NP in the practice confirm they have an active Open Payments registration, or create one now, before April 1.
- Nominate the compliance officer as authorized representative for clinicians who prefer not to review themselves.
- Start the industry interaction log for 2026 and ask clinicians to reconstruct 2025 from calendars as far as they can.
- Calendar April 1 for the review reminder, May 1 for a completion check and May 15 as the hard deadline.
- Draft or refresh the practice's written policy on industry meals, gifts and paid arrangements, and have counsel review it.
