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Nature of Payments

Reportable payments will fall into one of the following categories:

  • Consulting fees
  • Compensation for services other than consulting, including serving as faculty or as a speaker at an event other than a continuing education program
  • Honoraria
  • Gifts
  • Entertainment
  • Food and beverage
  • Travel and lodging
  • Education
  • Research
  • Charitable contributions
  • Royalty and license
  • Current or prospective ownership or investment interest
  • Compensation for serving as faculty or as a speaker for an accredited or certified continuing education program
  • Grants
  • Space rental or facility fees (teaching hospital only)

 

Exclusions include, among others:

  • Transfers of value that are under $10, unless the total aggregate value of all payments or transfers exceeds $100 during the reporting year; please note that these values reset each year
  • Educational materials that directly benefit the patient or intended for patient use (i.e. anatomical models, wall charts)
  • Product samples (including coupons and vouchers)

 

More information about “Open Payments” can be found on the CMS website http://www.cms.gov/openpayments/index.html.