What is the Sunshine Act and Open Payments?
The law that made every industry payment to a US doctor a public record — and what it does and does not cover.
The Physician Payments Sunshine Act, passed as part of the Affordable Care Act in 2010, requires drug and medical-device manufacturers to report almost every payment or transfer of value they make to a US physician or teaching hospital. The Centers for Medicare & Medicaid Services publishes those reports each June in a programme called Open Payments.
The premise is simple: financial relationships between industry and medicine are not inherently wrong, but they should not be invisible. A patient, a journalist or a hospital committee should be able to look them up.
What has to be reported
Any “transfer of value” of $10 or more, or smaller ones that add up past roughly $100 in a year. In practice that means:
- Meals at a practice or a restaurant
- Travel and lodging for a conference or advisory board
- Consulting fees and speaking fees
- Research funding, including payments routed through an institution
- Royalties on a patent the physician holds
- Gifts, entertainment, education materials, textbooks
- Ownership or investment interests in a manufacturer
Who has to report
“Applicable manufacturers” — companies making a drug, device, biological or medical supply that is reimbursable by Medicare, Medicaid or CHIP — and group purchasing organisations. The obligation is on the company, not the doctor. A physician does not file anything; they appear in the data because a company named them.
Who gets reported on
Originally physicians and teaching hospitals. From program year 2021 the definition widened to include physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anaesthetists and certified nurse-midwives.
What Open Payments does not cover
This matters more than most coverage admits:
- Payments to hospitals and health systems that are not teaching hospitals.
- Payments to pharmacists, dentists outside the covered definitions, and most allied health professionals — though dentists and optometrists are included as physicians under the statute.
- Product samples left with a practice.
- Payments below the reporting threshold that never accumulate past it.
- Anything from a company with no Medicare-reimbursable product.
So an empty record means “nothing reportable was reported”, not “this doctor has no industry relationships at all”. It is strong evidence, not proof.
How current is it?
CMS publishes annually, in June, covering the previous calendar year, and refreshes prior years at the same time as corrections come in. DocDollars queries the CMS API live, so what you see here is what CMS holds right now.