The Centers for Medicare and Medicaid Services (CMS) recently published their 2021 Open Payments data as well as newly submitted and updated payment records for previous program years. The 2021 report includes transactions that took place between January 1st and December 31st. Applicable manufacturers reported a total of $10.9 billion payments or transfers of value to healthcare professionals/organizations (HCP/Os) in 2021. The total amounts to approximately $3 billion more than calendar year 2020. Over 1,700 companies reported a total of 12.1 million records attributable to 533,056 physicians and 1,237 teaching hospitals.
The newly released Open Payments data is the first year of data to be released since the program expansion brought about by the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act of 2018 (SUPPORT Act). The SUPPORT Act added additional provider types as covered recipients for data collection, including:
- Physician Assistants
- Nurse Practitioners
- Clinical Nurse Specialists
- Certified Registered Nurse Anesthetists
- Anesthesiologist Assistants
- Certified Nurse Midwives
There were over 3.5 million payments made in 2021 against 233,471 additional non-physician practitioners accounting for almost $121.5 million of the spend for the year. In total the new practitioner types accounted for 29% of all transactions, but only a little over 1% of the total value reported.
According to the data published by CMS, $2.55 billion was attributed to general payments. Research payments totaled $7.09 billion, while ownership and investment interests accounted for $1.26 billion. Ownership interest remained almost identical to amounts reported in previous years. General payments increased by approximately half a billion dollars while the largest jump was seen in the increase in research spend for the year 2021. Research spend reportedly increased by more than one billion from the year 2020.
Food and beverage amounts for the year 2021 were nearly identical to years prior to the pandemic. This likely accounts for the additional practitioner types added as covered recipients as well as the beginning of a return to pre-pandemic activities, including in-person and virtual meals.
This publication is also the first year in which the new nature and purpose categories (acquisitions, debt forgiveness and long-term medical supply or device loan) were reported. Long-term device loans and debt forgiveness accounted for around $19 million in payments each while acquisitions had approximately $325 million in payments attributed to it.
The publishing of the 2021 Open Payments data and increase in overall spend serves as a reminder for companies to review their compliance policies and procedures related to HCP/O interactions. Ensuring accurate and complete reporting should continue to be a priority.
To learn more about how MediSpend can help support your Open Payments reporting obligations, please contact us.
The full set of CMS Open Payments data can be found here: https://openpaymentsdata.cms.gov/.
Lauren Howe
Compliance Attorney
July 22, 2022