What counts as a payment to a doctor? Meals, consulting fees, travel and more

The categories companies must use

Every general payment is labelled with a nature of payment. The federal rules list them as:

• Consulting fee
• Compensation for services other than consulting
• Compensation for serving as faculty or as a speaker for a medical education program
• Honoraria
• Gift
• Entertainment
• Food and beverage
• Travel and lodging
• Education
• Research
• Charitable contribution
• Royalty or license
• Grant
• Space rental or facility fees (teaching hospitals only)
• Long-term medical supply or device loan
• Debt forgiveness
• Acquisitions

Acquisitions, debt forgiveness, long-term medical supply or device loans, and the medical education speaker category were added or updated for payments made from 1 January 2021. Ownership and investment interests are reported as their own kind of record, and research agreements are reported as research payments — see the three kinds of money.

What the money was for in 2025

General payments reported for program year 2025, by nature of payment:

Food and beverage is the everyday end of the record: 14,764,648 records, about 92% of all general payment records that year, but a small share of the money. Large amounts tend to come from royalties, consulting and speaking.

What does not have to be reported

The rules exclude a number of things, including:

• product samples meant for patients, and educational materials that directly benefit patients;
• discounts and rebates;
• short-term loans of a device, for no more than 90 days in a year;
• items under warranty;
• payments to a doctor who is acting as a patient or a research subject, not as a professional;
• in-kind items for charity care;
• dividends from publicly traded securities and mutual funds;
• payments where the company does not know who the recipient is;
• payments for non-medical professional services, such as a doctor who is also a lawyer.

The small-payment threshold

Small items can be left out, but only while they stay small. A payment under the threshold does not have to be reported unless a company's payments to the same person add up to more than the annual amount — at which point every one of them must be reported. The amounts rise with inflation each year:

Source: CMS, Open Payments data collection.