Have Financial Relationships Between Manufacturers and Practitioners Returned to Pre-Pandemic Levels?

In November 2023, the Office of Inspector General (OIG) of the US Department of Health and Human Services (HHS) published its first major update to compliance program guidance in fifteen years. The modernized General Compliance Program Guidance (GCPG) is intended to serve as a reference guide for the entire healthcare industry. The guidance consolidates into one resource the industry standards for, among other things, the financial arrangements between entities engaged in the business of healthcare.

To evaluate the changes in financial arrangements between healthcare manufacturers and physicians due to the COVID-19 pandemic, we analyzed the publicly available Open Payments database for program years 2017 through 2022. The Affordable Care Act requires the Centers for Medicare and Medicaid Services (CMS) to collect and publish data on the financial relationships between healthcare manufacturers and certain “covered recipients,” including physician practitioners, in the Open Payments database. For each reported transfer of value (“payment”), manufacturers are required to include the nature and value of the payment, the recipient, and the associated product.

For the purposes of this study, we focus on the payments most frequently associated with physician provision of a service funded by a healthcare manufacturer. This includes research payments, consulting fees, non-education-related speaking fees, education-related speaking fees, and honoraria. To compare against pre-pandemic trends, each type of payment is aggregated annually, and all values are reported in 2022 inflation-adjusted dollars.

Our analysis seeks to answer the following questions:

1. Which financial arrangements between healthcare manufacturers and physicians were most significantly impacted by the COVID-19 pandemic?
2. Have these financial arrangements returned to pre-pandemic levels? Or has the pandemic altered these arrangements going forward?