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.
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.
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.
⊞ data table⬇ CSV
| Year | Total (USD billions) | General (USD billions) | Research (USD billions) | Payment records (millions) |
|---|---|---|---|---|
| 2018 | 11.07 | 3.12 | 6.3 | 11.74 |
| 2019 | 11.98 | 3.72 | 6.64 | 11.37 |
| 2020 | 10.63 | 2.19 | 7.05 | 6.61 |
| 2021 | 12.64 | 3.27 | 7.82 | 12.29 |
| 2022 | 13.11 | 3.84 | 8.11 | 14.31 |
| 2023 | 13.14 | 3.32 | 8.43 | 15.79 |
| 2024 | 13.18 | 3.33 | 8.52 | 16.16 |
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.
⊞ data table⬇ CSV
| Year | General (USD billions) | Research (USD billions) | Ownership and investment (USD billions) | Total (USD billions) |
|---|---|---|---|---|
| 2018 | 3.12 | 6.3 | 1.65 | 11.07 |
| 2019 | 3.72 | 6.64 | 1.62 | 11.98 |
| 2020 | 2.19 | 7.05 | 1.39 | 10.63 |
| 2021 | 3.27 | 7.82 | 1.56 | 12.64 |
| 2022 | 3.84 | 8.11 | 1.16 | 13.11 |
| 2023 | 3.32 | 8.43 | 1.39 | 13.14 |
| 2024 | 3.33 | 8.52 | 1.34 | 13.18 |
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.
⊞ data table⬇ CSV
| Specialty | Cumulative general payments (USD millions) | Physicians paid | Percent of specialty paid |
|---|---|---|---|
| Orthopedic Surgery | 1360.7 | 31620 | 65 |
| Neurology / Psychiatry | 1322.7 | 58688 | 54.5 |
| Cardiology | 1293.6 | 33074 | 71.6 |
| Hematology / Oncology | 825.8 | 17025 | 74.2 |
| General Internal Medicine | 588.2 | 97542 | 55.4 |
| Endocrinology | 546.5 | 8211 | 70.7 |
| Family Medicine | 479.1 | 110692 | 54.6 |
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.
⊞ data table⬇ CSV
| Specialty | Payment per paid physician (USD) | Physicians paid | Cumulative general payments (USD millions) |
|---|---|---|---|
| Endocrinology | 66557 | 8211 | 546.5 |
| Hematology / Oncology | 48505 | 17025 | 825.8 |
| Orthopedic Surgery | 43033 | 31620 | 1360.7 |
| Cardiology | 39112 | 33074 | 1293.6 |
| Neurology / Psychiatry | 22538 | 58688 | 1322.7 |
| General Internal Medicine | 6030 | 97542 | 588.2 |
| Family Medicine | 4328 | 110692 | 479.1 |
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.
⊞ data table⬇ CSV
| Specialty | Share of specialty paid (percent) | Physicians paid |
|---|---|---|
| Hematology / Oncology | 74.2 | 17025 |
| Cardiology | 71.6 | 33074 |
| Endocrinology | 70.7 | 8211 |
| Orthopedic Surgery | 65 | 31620 |
| General Internal Medicine | 55.4 | 97542 |
| Family Medicine | 54.6 | 110692 |
| Neurology / Psychiatry | 54.5 | 58688 |
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.
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.
⊞ data table⬇ CSV
| Brand combination vs generic | Odds ratio, any payment | Odds ratio, manufacturer-specific payment |
|---|---|---|
| Naproxen + esomeprazole | 1.45 | 5.96 |
| Amlodipine + olmesartan | 1.42 | 2.4 |
| Saxagliptin + metformin | 1.5 | 2.21 |
| Ibuprofen + famotidine | not published | 8.06 |
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.
⊞ data table⬇ CSV
| Drug (HCPCS) | Medicare-allowed amount (USD) | Billing providers (approx) | Allowed per provider (USD) |
|---|---|---|---|
| Aflibercept (J0178) | 3355052359 | 4092 | 819905 |
| Pembrolizumab (J9271) | 1852967375 | 4998 | 370742 |
| Denosumab (J0897) | 1184059418 | 34430 | 34390 |
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.
⊞ data table⬇ CSV
| HCPCS | Description | Physician-administered drug | Billing providers (approx) | Medicare-allowed amount (USD) |
|---|---|---|---|---|
| 99214 | Established patient office or other outpatient visit, 30-3 | no | 762825 | 11796083200 |
| 99213 | Established patient office or other outpatient visit, 20-2 | no | 753221 | 6296169803 |
| J0178 | Injection, aflibercept, 1 mg | yes | 4092 | 3355052359 |
| 99233 | Follow-up hospital inpatient care per day, typically 35 mi | no | 256533 | 2590719359 |
| 99232 | Follow-up hospital inpatient care per day, typically 25 mi | no | 307309 | 2469558438 |
| 99204 | New patient office or other outpatient visit, 45-59 minute | no | 546491 | 1978097405 |
| 66984 | Removal of cataract with insertion of prosthetic lens | no | 29183 | 1970028572 |
| 99215 | Established patient office or other outpatient visit, 40-5 | no | 408509 | 1894380835 |
| J9271 | Injection, pembrolizumab, 1 mg | yes | 4998 | 1852967375 |
| A0427 | Ambulance service, advanced life support, emergency transp | no | 8259 | 1837782403 |
| 99223 | Initial hospital inpatient care per day, typically 70 minu | no | 252191 | 1743548243 |
| 99285 | Emergency department visit for life threatening or functio | no | 89188 | 1586226272 |
| 97110 | Therapy procedure using exercise to develop strength, endu | no | 98839 | 1489681856 |
| 99291 | Critical care, first 30-74 minutes | no | 137183 | 1244786900 |
| J0897 | Injection, denosumab, 1 mg | yes | 34430 | 1184059418 |
| 92014 | Established patient complete exam of visual system | no | 46766 | 1180580749 |
| G0439 | Annual wellness visit, includes a personalized prevention | no | 150032 | 1129387524 |
| A0429 | Ambulance service, basic life support, emergency transport | no | 9371 | 1062667726 |
| K1034 | Provision of covid-19 test, nonprescription self-administe | no | 35788 | 1054999982 |
| 99203 | New patient office or other outpatient visit, 30-44 minute | no | 474713 | 1033858854 |
| 97530 | Therapy procedure using functional activities | no | 83573 | 981532291 |
| 88305 | Pathology examination of tissue using a microscope, interm | no | 22817 | 929480304 |
| 99309 | Follow-up nursing facility visit per day, typically 25 min | no | 56708 | 901475803 |
| A0425 | Ground mileage, per statute mile | no | 9933 | 883992366 |
| 93306 | Ultrasound of heart with color-depicted blood flow, rate | no | 50406 | 787291194 |
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
- Report to Congress, FY2025 Annual Report on the Open Payments Program (CMS) · 2026
- Facts about Open Payments data (CMS) · 2025
- Industry Payments to US Physicians by Specialty and Product Type (JAMA) · 2024
- Association between industry payments and prescribing costly medications (BMC Health Services Research) · 2018
- Medicare Physician and Other Practitioners by Geography and Service, CY2022 (CMS) · 2022
- Dollars for Docs (ProPublica) · 2025