CMS recently released Open Payments data submitted by applicable pharmaceutical and medical device manufacturers for calendar year 2015, and it is now available here. The 2015 data set includes an astonishing 11.9 million records of physicians’ ownership or investment interests and of payments made to teaching hospitals and physicians, for a grand total of $7.92 billion.

CMS attempted to characterize the 2015 data in a blog post, but it raises more questions than it answers in its post. For example, CMS noted that, for program year 2015, 2.26% of all financial transactions between physicians and pharmaceutical companies were related to opioid medications. Without context for this figure, it’s not clear what to make of it – are we to think that opioid prescriptions are being improperly driven by these financial transactions? Or find this to be a sign that opioid research funding needs to increase? Or simply file this away as an interesting, if meaningless, cocktail party fact?

CMS also noted a shift away from payments classified as “gifts” and “honoraria” towards payments classified as “charitable contributions,” attributing this shift to physicians empowered by transparency to “be more purposeful about their financial relationships with companies.” This interpretation may be a stretch, as the shift could just as easily be attributed to companies’ desire for the public to see them as more focused on philanthropy.

Perhaps our expectations for Open Payments data are too high.  CMS does admit that the Open Payments program does not identify whether financial relationships are beneficial or whether they may indicate problematic conflicts of interest; rather, the Open Payments program is intended to shed light on the nature and extent of financial relationships between physicians and teaching hospitals and the pharmaceutical and medical device industries. However, without providing context for or interpretation of the data, it seems of little use to the public. Thinking about the resources dedicated by pharmaceutical and device manufacturers to tracking, verifying, reporting, and reviewing 11.9 million payment and investment interest records, it is not clear that this time and effort yields sufficient useful information to make the herculean task worthwhile. Perhaps, as more data is reported, interesting trends and useful information will emerge – only time will tell.