off label.

Conflicts of interest

Where does promoted-drug money land in Medicare, and which drugs concentrate the most spend in the fewest prescribers?

Drug and device makers reported $13.18 billion in payments to clinicians and teaching hospitals in 2024, the most on record. Payments concentrate in a handful of procedure-heavy specialties, and clinicians who take manufacturer-specific payments are far more likely to prescribe that maker's costly brand-name drug.

Question

The problem

Financial conflicts can shape clinical decision-making across the national care landscape when industry payments concentrate among specialties, prescribers, and high-spend physician-administered drugs. The trust problem is not every payment, but the absence of actionable context at the moment a patient, plan, or health system evaluates care choices.

The recommendation

Move conflict transparency from passive disclosure to point-of-decision governance. The recommended approach is to connect relevant manufacturer payments to prescribing and formulary review, prioritize high-spend physician-administered drugs, and strengthen oversight where payment concentration and prescribing concentration overlap.

The payments

Size, growth, concentration, and reach of the money flowing from industry to clinicians, before any effect is argued.

$13.18B
in industry payments to clinicians and teaching hospitals in 2024
The highest annual total on record, up from $11.07B in 2018.
38.6%
of physicians took at least one industry payment
Across 667,278 physicians studied. Taking money is the norm, not the exception.
16.16M
industry payment records logged in 2024
About 44,000 transfers of value every day.

Total industry payments to clinicians and teaching hospitals, 2018 to 2024

All CMS Open Payments categories combined. General payments and record counts fell in 2020 as COVID-19 curtailed in-person meals and events. Research payments kept rising.

Read it this way The 2020 dip shows up even more sharply in the transaction count than in the dollar total: payment records fell to 6.61 million that year from 11.37 million in 2019, roughly half, while the dollar total only dropped from $11.98 billion to $10.63 billion. That gap licenses the conclusion that fewer individual transactions happened, not that manufacturers cut what they paid per transaction. Use this chart to see where payment influence or spending concentration appears, and why the recommendation targets transparency at prescribing and formulary decision points.

$0B $5B $10B $15B $20B 2018201920202021202220232024 Total payments
Year
⊞ data table⬇ CSV
YearTotal (USD billions)General (USD billions)Research (USD billions)Payment records (millions)
201811.073.126.311.74
201911.983.726.6411.37
202010.632.197.056.61
202112.643.277.8212.29
202213.113.848.1114.31
202313.143.328.4315.79
202413.183.338.5216.16

CMS, Open Payments FY2025 Report to Congress · 2018-2024 · source

What kind of industry money is growing: research, general, and ownership

Each year's total split into research payments, general payments (meals, speaking, consulting, travel), and ownership or investment interests. The near-flat total hides that research is the only band that keeps growing.

Read it this way Research payments rose every single year, from $6.3 billion in 2018 to $8.52 billion in 2024, while general payments swung as low as $2.19 billion in 2020 and ownership interests slowly shrank from $1.65 billion to $1.34 billion. It is the steadily climbing research band, not the more volatile general-payment band, that is pushing the total higher. Use this chart to see where payment influence or spending concentration appears, and why the recommendation targets transparency at prescribing and formulary decision points.

$0B $5B $10B $15B $20B 2018201920202021202220232024 Research General Ownership and investment
⊞ data table⬇ CSV
YearGeneral (USD billions)Research (USD billions)Ownership and investment (USD billions)Total (USD billions)
20183.126.31.6511.07
20193.726.641.6211.98
20202.197.051.3910.63
20213.277.821.5612.64
20223.848.111.1613.11
20233.328.431.3913.14
20243.338.521.3413.18

CMS, Open Payments FY2025 Report to Congress · 2018-2024 · source

Industry general payments by physician specialty

Cumulative general payments (consulting, speaking, meals, travel, gifts, education) August 2013 through December 2022, physicians only.

Read it this way Orthopedic surgery, neurology/psychiatry, and cardiology each drew more than $1.2 billion cumulatively, but that ranking mixes how many physicians work in a specialty with how much industry paid each one. It cannot show the per-physician size of the payment. The next chart divides these same totals by physician count to answer that. Use this chart to see where payment influence or spending concentration appears, and why the recommendation targets transparency at prescribing and formulary decision points.

Caveat These cumulative multi-year, physician-only, general-payment totals are not comparable to the single-year all-recipient program totals shown in the trend chart. Research and ownership payments are excluded.

$0M $500M $1,000M $1,500M $2,000M Orthopedic Surgery $1,360.7M Neurology / Psychiatry $1,322.7M Cardiology $1,293.6M Hematology / Oncology $825.8M General Internal Medicine $588.2M Endocrinology $546.5M Family Medicine $479.1M
Year
⊞ data table⬇ CSV
SpecialtyCumulative general payments (USD millions)Physicians paidPercent of specialty paid
Orthopedic Surgery1360.73162065
Neurology / Psychiatry1322.75868854.5
Cardiology1293.63307471.6
Hematology / Oncology825.81702574.2
General Internal Medicine588.29754255.4
Endocrinology546.5821170.7
Family Medicine479.111069254.6

JAMA, Industry Payments to US Physicians by Specialty · 2024 · source

Average industry payment per paid physician, by specialty

Cumulative general payments August 2013 to December 2022 divided by the number of physicians in each specialty who were paid. Raw dollars reward big fields, but per paid doctor, the ranking flips.

Read it this way Endocrinology tops this list at $66,557 per paid physician even though its $546.5 million cumulative total was one of the smallest in the prior chart, because only 8,211 endocrinologists split it. Family medicine sits at the bottom at $4,328 per physician despite a larger $479.1 million total, because 110,692 physicians shared it: concentration among fewer doctors matters as much as the size of the total. Use this chart to see where payment influence or spending concentration appears, and why the recommendation targets transparency at prescribing and formulary decision points.

Caveat Derived by dividing each specialty's cumulative general-payment total by its count of paid physicians. Both figures are physician-only, general-payments-only, and cumulative, so they are not comparable to single-year program totals.

$0 $25,000 $50,000 $75,000 $100,000 Endocrinology $66,557 Hematology / Oncology $48,505 Orthopedic Surgery $43,033 Cardiology $39,112 Neurology / Psychiatry $22,538 General Internal Medicine $6,030 Family Medicine $4,328
⊞ data table⬇ CSV
SpecialtyPayment per paid physician (USD)Physicians paidCumulative general payments (USD millions)
Endocrinology665578211546.5
Hematology / Oncology4850517025825.8
Orthopedic Surgery43033316201360.7
Cardiology39112330741293.6
Neurology / Psychiatry22538586881322.7
General Internal Medicine603097542588.2
Family Medicine4328110692479.1

JAMA, Industry Payments to US Physicians by Specialty · 2024 · source

Share of each specialty that took any industry payment

Percent of physicians in each specialty who received at least one industry general payment, cumulative August 2013 to December 2022.

Read it this way Every specialty listed here clears 54 percent, and hematology/oncology reaches 74.2 percent, all well above the often-cited 38.6 percent physician-wide figure noted in the caveat. That gap exists because the 38.6 percent number comes from a different, older study with a different denominator, so read the two figures as complementary evidence, not directly comparable ones, that taking industry money is routine in procedure- and drug-heavy specialties. Use this chart to see where payment influence or spending concentration appears, and why the recommendation targets transparency at prescribing and formulary decision points.

Caveat The workforce-wide figure that 38.6 percent of all physicians take industry money comes from a different study and denominator (a 2014 Medicare Part D linkage), so it is described rather than drawn here as a reference line.

0.0% 25.0% 50.0% 75.0% 100.0% Hematology / Oncology 74.2% Cardiology 71.6% Endocrinology 70.7% Orthopedic Surgery 65.0% General Internal Medicine 55.4% Family Medicine 54.6% Neurology / Psychiatry 54.5%
⊞ data table⬇ CSV
SpecialtyShare of specialty paid (percent)Physicians paid
Hematology / Oncology74.217025
Cardiology71.633074
Endocrinology70.78211
Orthopedic Surgery6531620
General Internal Medicine55.497542
Family Medicine54.6110692
Neurology / Psychiatry54.558688

JAMA, Industry Payments to US Physicians by Specialty · 2024 · source

Money and prescribing

What the money is associated with, and where the promoted-drug dollars land in Medicare Part B.

5.96×
higher odds of prescribing naproxen plus esomeprazole over a generic after a payment from its maker
Versus 1.45 times for any industry payment. Association, not proof of causation.
$820K
in Medicare-allowed spend per aflibercept-billing provider
$3.36B concentrated across about 4,092 billing providers in 2022. A small, high-leverage prescriber base.

Odds of prescribing the brand drug: any payment vs the maker's own payment

For each brand-name combination, the adjusted odds of prescribing it over a cheaper generic. Money from the drug's own maker tracks far more strongly than any industry payment. A value of 1.0 means no association.

Read it this way In every combination, the manufacturer's own payment carries a higher odds ratio than any industry payment, peaking at 5.96 for naproxen plus esomeprazole and 8.06 for ibuprofen plus famotidine. These are statistical associations from observational studies, not proof the payment caused the prescription, and the reference line at 1.0 marks where a payment would show no relationship at all. Use this chart to see where payment influence or spending concentration appears, and why the recommendation targets transparency at prescribing and formulary decision points.

Caveat These studies show association, not proof that a payment caused the prescribing choice. Ibuprofen plus famotidine has no published any-payment odds ratio, so only its manufacturer-specific bar is shown.

0.00× 2.50× 5.00× 7.50× 10.00× 1.45× 5.96× Naproxen + esomeprazole 1.42× 2.40× Amlodipine + olmesartan 1.50× 2.21× Saxagliptin + metformin 8.06× Ibuprofen + famotidine no association (1.0) Any industry payment Manufacturer's own payment
⊞ data table⬇ CSV
Brand combination vs genericOdds ratio, any paymentOdds ratio, manufacturer-specific payment
Naproxen + esomeprazole1.455.96
Amlodipine + olmesartan1.422.4
Saxagliptin + metformin1.52.21
Ibuprofen + famotidinenot published8.06

BMC Health Services Research, industry payments and prescribing · 2018 · source

Physician-administered drugs that concentrate the most Medicare Part B money

Total Medicare-allowed amount for the three physician-administered (J-code) drugs among the highest-spend Part B billing codes in 2022. These injectables are marketed to the same specialties that draw the most industry payments.

Read it this way Aflibercept alone accounts for $3.36 billion of Medicare Part B spend, nearly twice pembrolizumab's $1.85 billion and almost three times denosumab's $1.18 billion. This shows relative scale among only the three physician-administered drugs flagged in this top-procedures sample, not a complete ranking of all Medicare drug spending. Use this chart to see where payment influence or spending concentration appears, and why the recommendation targets transparency at prescribing and formulary decision points.

Caveat Only three billing codes in this top-procedures sample are flagged as physician-administered drugs. A complete J-code ranking would need the full CMS Part B public use file.

$0B $1.3B $2.5B $3.8B $5B Aflibercept (J0178) eye, macular degeneration $3.4B Pembrolizumab (J9271) cancer immunotherapy $1.9B Denosumab (J0897) bone, osteoporosis $1.2B
⊞ data table⬇ CSV
Drug (HCPCS)Medicare-allowed amount (USD)Billing providers (approx)Allowed per provider (USD)
Aflibercept (J0178)33550523594092819905
Pembrolizumab (J9271)18529673754998370742
Denosumab (J0897)11840594183443034390

CMS, Medicare Physician and Other Practitioners by Geography and Service · 2022 · source

Spend versus prescriber base: how few providers control the drug dollars

Each point is one of the 25 highest-spend Medicare Part B billing codes in 2022. The three physician-administered drugs (in coral) sit in the low-provider, high-dollar corner.

Read it this way The three coral points sit far to the left and high up: aflibercept at 4,092 providers for $3.36 billion, pembrolizumab at 4,998 providers for $1.85 billion, denosumab at 34,430 providers for $1.18 billion, while the muted office-visit codes cluster at hundreds of thousands of providers for comparable or lower total spend. That pattern shows physician-administered drug dollars concentrate in far fewer hands than routine office-visit billing, though the provider counts are an approximate upper bound, not an exact count. Use this chart to see where payment influence or spending concentration appears, and why the recommendation targets transparency at prescribing and formulary decision points.

Caveat Provider counts are an approximate upper bound. They sum facility and non-facility rows per code, so a provider billing a code in both settings is counted twice.

$0B $5B $10B $15B $20B 0250,000500,000750,0001,000,000 99214 · Established patient office 99213 · Established patient office J0178 · Injection, aflibercept, 1 mg 99233 · Follow-up hospital inpatient 99232 · Follow-up hospital inpatient 99204 · New patient office 66984 · Cataract removal with lens 99215 · Established patient office J9271 · Injection, pembrolizumab, 1 mg A0427 · Ambulance, advanced life support 99223 · Initial hospital inpatient care 99285 · Emergency department visit 97110 · Therapeutic exercise 99291 · Critical care, first 30-74 min J0897 · Injection, denosumab, 1 mg 92014 · Established patient eye exam G0439 · Annual wellness visit A0429 · Ambulance, basic life support K1034 · COVID-19 self-test 99203 · New patient office 97530 · Therapeutic activities 88305 · Tissue pathology exam 99309 · Nursing facility visit A0425 · Ground ambulance mileage 93306 · Echocardiogram with Doppler BILLING PROVIDERS (APPROX) MEDICARE-ALLOWED AMOUNT (USD BILLIONS)
⊞ data table⬇ CSV
HCPCSDescriptionPhysician-administered drugBilling providers (approx)Medicare-allowed amount (USD)
99214Established patient office or other outpatient visit, 30-3no76282511796083200
99213Established patient office or other outpatient visit, 20-2no7532216296169803
J0178Injection, aflibercept, 1 mgyes40923355052359
99233Follow-up hospital inpatient care per day, typically 35 mino2565332590719359
99232Follow-up hospital inpatient care per day, typically 25 mino3073092469558438
99204New patient office or other outpatient visit, 45-59 minuteno5464911978097405
66984Removal of cataract with insertion of prosthetic lensno291831970028572
99215Established patient office or other outpatient visit, 40-5no4085091894380835
J9271Injection, pembrolizumab, 1 mgyes49981852967375
A0427Ambulance service, advanced life support, emergency transpno82591837782403
99223Initial hospital inpatient care per day, typically 70 minuno2521911743548243
99285Emergency department visit for life threatening or functiono891881586226272
97110Therapy procedure using exercise to develop strength, enduno988391489681856
99291Critical care, first 30-74 minutesno1371831244786900
J0897Injection, denosumab, 1 mgyes344301184059418
92014Established patient complete exam of visual systemno467661180580749
G0439Annual wellness visit, includes a personalized preventionno1500321129387524
A0429Ambulance service, basic life support, emergency transportno93711062667726
K1034Provision of covid-19 test, nonprescription self-administeno357881054999982
99203New patient office or other outpatient visit, 30-44 minuteno4747131033858854
97530Therapy procedure using functional activitiesno83573981532291
88305Pathology examination of tissue using a microscope, intermno22817929480304
99309Follow-up nursing facility visit per day, typically 25 minno56708901475803
A0425Ground mileage, per statute mileno9933883992366
93306Ultrasound of heart with color-depicted blood flow, rateno50406787291194

CMS, Medicare Physician and Other Practitioners by Geography and Service · 2022 · source

Why this matters

Open Payments discloses this money in a federal database, not at the point of care, so the disclosure exists but isn't seen when a prescribing decision is actually made. Growth is driven specifically by research payments (up steadily from $6.3 billion to $8.52 billion), the least visible category to patients. Because taking payments is the norm, 38.6 percent of physicians overall and well over half in every specialty studied, this is baseline practice, not a fringe conflict, and the strongest prescribing associations are tied to a drug's own manufacturer rather than any industry payment.

Recommended actions

  • Require point-of-care disclosure: when a prescriber recommends a brand-name drug or device, surface any payment they've received from that specific manufacturer in the past year.
  • Prioritize disclosure in the highest-concentration specialties and drugs (orthopedic surgery, cardiology, hematology/oncology, aflibercept-class injectables) where per-physician payments and prescribing associations are largest.
  • Distinguish research payments from general payments (meals, speaking, consulting) in any patient-facing disclosure, since they carry different implications and research is the fastest-growing category.
  • Fund independent research replicating the manufacturer-specific odds-ratio studies across more drug classes to test whether the association generalizes.
  • Monitor Open Payments data annually for shifts in specialty concentration rather than treating the current ranking as fixed.

The recommendation

Therefore, move conflict transparency from passive disclosure to point-of-decision governance. The recommended approach is to connect relevant manufacturer payments to prescribing and formulary review, prioritize high-spend physician-administered drugs, and strengthen oversight where payment concentration and prescribing concentration overlap.

Demographic slice none. Open Payments records paying company and receiving physician, not patient demographics.

Sources