{ "study": { "slug": "industry-payments-to-excluded-providers-2026", "title": "Industry payments to providers on the OIG exclusion list", "standfirst": "In program year 2024, drug and device manufacturers reported $3.84 million in Open Payments to 294 physicians and other providers who now sit on the federal OIG exclusion list, spread across 3,055 separate transfers. A single category — debt forgiveness — accounts for $3.27 million of that total.", "desk": "financial-distress", "article_type": "Original Research", "published": "2026-06-14", "issue": 55, "doi": "10.5072/fonteum/industry-payments-to-excluded-providers-2026", "url": "https://fonteum.com/research/industry-payments-to-excluded-providers-2026", "methodology_version": "industry-payments-exclusions/v1" }, "data_as_of": "2026-06-14", "datasets": [ { "slug": "cms-open-payments", "name": "CMS Open Payments", "publisher": "CMS — Open Payments", "upstream_url": null }, { "slug": "oig-leie", "name": "OIG LEIE", "publisher": "HHS OIG — List of Excluded Individuals/Entities", "upstream_url": null } ], "key_findings": [ { "number": "$3.84M", "finding": "in industry Open Payments reached 294 providers who now sit on the federal OIG exclusion list, across 3,055 program-year 2024 transfers", "dataset": "open-payments" }, { "number": "294", "finding": "currently-excluded providers received industry payments — 4.3% of the 6,880 NPI-identified individuals on the federal OIG LEIE", "dataset": "oig-leie" }, { "number": "$209,758", "finding": "moved in 855 payments dated after the provider's OIG exclusion had already taken effect, reaching 181 providers", "dataset": "open-payments" }, { "number": "85.1%", "finding": "of the dollars — $3.27M — is debt forgiveness, concentrated in 11 providers and one orthobiologics manufacturer", "dataset": "open-payments" } ], "faqs": [ { "q": "How much did industry pay providers who are on the federal exclusion list?", "a": "Drug and device manufacturers reported $3.84 million in program-year 2024 Open Payments to 294 providers who now appear on the federal OIG List of Excluded Individuals and Entities. The payments span 3,055 separate records, and a single category — debt forgiveness — makes up $3.27 million of the total." }, { "q": "Does an Open Payments record mean the payment was illegal?", "a": "No. An OIG exclusion bars a provider from billing Medicare, Medicaid, and other federal programs; it does not prohibit a manufacturer from reporting a transfer of value. An Open Payments record is a disclosure, not a finding of wrongdoing, and most of these dollars are dated before the provider's exclusion took effect." }, { "q": "How many excluded providers received industry payments?", "a": "294 of the 6,880 NPI-identified individuals on the federal OIG LEIE — about 4.3%, or one in 23 — appear as recipients in the program-year 2024 Open Payments file. The other 61,030 LEIE records carry no NPI and cannot be matched to a payment by identifier, so they are reported separately." }, { "q": "Were any payments made after the provider was excluded?", "a": "Yes. $209,758 across 855 payments carries a payment date after the provider's OIG exclusion had already taken effect, reaching 181 providers. These are mostly small food-and-beverage transfers. The larger sums — including the $3.27 million in debt forgiveness — are dated on or before the exclusion date." }, { "q": "Which manufacturers paid excluded providers the most?", "a": "By dollars, one orthobiologics maker, Skye Orthobiologics, reported $3.20 million in two debt-forgiveness records — 83% of the entire total. By reach, AbbVie touched the most excluded providers, 78 of them, almost entirely through small food-and-beverage transfers. CSL Plasma reported $389,671 across 439 records." }, { "q": "Why does the analysis cover only program year 2024?", "a": "The ingested CMS Open Payments snapshot holds program year 2024. CMS publishes the program annually under the Physician Payments Sunshine Act, and 2024 is the most recent complete file. As earlier program years are added, the same NPI join re-runs and the matched totals extend backward." }, { "q": "Can I reproduce these numbers?", "a": "Yes. Every figure is a direct NPI join between the public cms_open_payments and oig_leie_exclusions tables. The exact SQL is published in the reproducibility block below; each count resolves to specific rows in specific frozen snapshots, and no match is ever inferred from a name." } ], "citation": { "apa": "Fonteum Research. (2026, June 14). Industry payments to providers on the OIG exclusion list. Fonteum Research, Issue 55. https://doi.org/10.5072/fonteum/industry-payments-to-excluded-providers-2026", "url": "https://fonteum.com/research/industry-payments-to-excluded-providers-2026" }, "reproducible_sql": "-- Industry payments to OIG-excluded providers — fully reproducible query.\n--\n-- Question: how much did drug and device manufacturers pay, through CMS Open\n-- Payments, to providers who appear on the federal OIG exclusion list (LEIE)?\n--\n-- Sources:\n-- public.cms_open_payments — CMS Open Payments, manufacturer-reported\n-- transfers of value under the Physician Payments\n-- Sunshine Act. Program year 2024 (the ingested\n-- snapshot). general / research / ownership\n-- record_types. public, read-only.\n-- public.oig_leie_exclusions — OIG List of Excluded Individuals/Entities,\n-- federal monthly bulk download, release\n-- 2026-05-08, 68,055 active records (7,025 rows\n-- with an NPI; 6,880 distinct NPIs). public, read-only.\n--\n-- Join key: NPI only (10-digit, btrim). We never match on name — a name match is\n-- not a defensible identity assertion, so the 61,030 LEIE rows with no NPI are\n-- excluded from the matchable denominator and reported separately (query 5).\n--\n-- \"In force\" mirrors the production exclusion lookup (src/lib/exclusions): a row\n-- is in force when reinstatement_date IS NULL OR reinstatement_date > today. The\n-- OIG drops reinstated parties from the published file, so this set equals every\n-- LEIE NPI on record. Date basis: current_date (2026-06-14 at publish).\n--\n-- Every headline figure in the study resolves to one of the queries below.\n\n-- The excluded-provider set, reused below: distinct in-force LEIE NPIs.\n-- (Inlined as a CTE in each query so every query stands alone.)\n\n-- 1) HEADLINE — total industry dollars to currently-excluded providers.\nWITH excl AS (\n SELECT DISTINCT btrim(npi) AS npi\n FROM public.oig_leie_exclusions\n WHERE nullif(btrim(npi), '') IS NOT NULL\n AND (reinstatement_date IS NULL OR reinstatement_date > current_date)\n)\nSELECT\n count(DISTINCT op.recipient_npi) AS excluded_providers_paid, -- 294\n count(*) AS payment_records, -- 3,055\n round(sum(op.total_amount_usd), 2) AS total_usd -- 3,835,221.38\nFROM public.cms_open_payments op\nJOIN excl ON op.recipient_npi = excl.npi;\n-- excluded_providers_paid payment_records total_usd\n-- 294 3,055 3,835,221.38\n\n-- 2) BREAKDOWN BY PROGRAM YEAR. (The ingested snapshot holds program year 2024\n-- only; as earlier years are added, this query extends backward unchanged.)\nWITH excl AS (\n SELECT DISTINCT btrim(npi) AS npi\n FROM public.oig_leie_exclusions\n WHERE nullif(btrim(npi), '') IS NOT NULL\n AND (reinstatement_date IS NULL OR reinstatement_date > current_date)\n)\nSELECT op.program_year,\n count(DISTINCT op.recipient_npi) AS excluded_providers,\n count(*) AS payment_records,\n round(sum(op.total_amount_usd), 2) AS total_usd\nFROM public.cms_open_payments op\nJOIN excl ON op.recipient_npi = excl.npi\nGROUP BY op.program_year\nORDER BY op.program_year;\n-- program_year excluded_providers payment_records total_usd\n-- 2024 294 3,055 3,835,221.38\n\n-- 3) TOP PAYING MANUFACTURERS (by dollars to excluded providers).\nWITH excl AS (\n SELECT DISTINCT btrim(npi) AS npi\n FROM public.oig_leie_exclusions\n WHERE nullif(btrim(npi), '') IS NOT NULL\n AND (reinstatement_date IS NULL OR reinstatement_date > current_date)\n)\nSELECT op.manufacturer_name,\n count(DISTINCT op.recipient_npi) AS excluded_providers_paid,\n count(*) AS payment_records,\n round(sum(op.total_amount_usd), 2) AS total_usd\nFROM public.cms_open_payments op\nJOIN excl ON op.recipient_npi = excl.npi\nGROUP BY op.manufacturer_name\nORDER BY total_usd DESC\nLIMIT 10;\n-- manufacturer_name excluded_providers records total_usd\n-- Skye Orthobiologics LLC 2 2 3,196,265.00\n-- CSL Plasma Inc. 2 439 389,670.97\n-- ConvaTec Inc. 1 18 45,120.00\n-- Teva Pharmaceuticals USA, Inc. 4 30 20,728.41\n-- Intra-Cellular Therapies, Inc. 11 80 18,756.73\n-- Alkermes, Inc. 8 48 18,185.45\n-- Otsuka America Pharmaceutical 18 60 16,207.26\n-- AbbVie Inc. 78 351 11,832.99 (widest reach)\n\n-- 4) BY NATURE OF PAYMENT — where the dollars concentrate vs. where the contact\n-- is broadest. Debt forgiveness is 85.1% of dollars; food & beverage reaches\n-- 274 of the 294 providers.\nWITH excl AS (\n SELECT DISTINCT btrim(npi) AS npi\n FROM public.oig_leie_exclusions\n WHERE nullif(btrim(npi), '') IS NOT NULL\n AND (reinstatement_date IS NULL OR reinstatement_date > current_date)\n)\nSELECT op.nature_of_payment,\n count(DISTINCT op.recipient_npi) AS excluded_providers,\n count(*) AS payment_records,\n round(sum(op.total_amount_usd), 2) AS total_usd\nFROM public.cms_open_payments op\nJOIN excl ON op.recipient_npi = excl.npi\nGROUP BY op.nature_of_payment\nORDER BY total_usd DESC;\n-- nature_of_payment providers records total_usd\n-- Debt forgiveness 11 29 3,265,237.00\n-- Consulting Fee 6 445 403,920.97\n-- Food and Beverage 274 2,460 64,588.74\n-- Compensation (speaking) 8 27 51,150.43\n-- ... (long tail omitted)\n\n-- 5) TIMING — payments dated AFTER the provider's exclusion took effect, vs. on\n-- or before. Uses the earliest excl_date per NPI. A provider with payments on\n-- both sides is counted in both rows.\nWITH excl AS (\n SELECT btrim(npi) AS npi, min(excl_date) AS first_excl_date\n FROM public.oig_leie_exclusions\n WHERE nullif(btrim(npi), '') IS NOT NULL\n AND (reinstatement_date IS NULL OR reinstatement_date > current_date)\n GROUP BY btrim(npi)\n)\nSELECT\n CASE WHEN op.payment_date > e.first_excl_date\n THEN 'dated_after_exclusion'\n ELSE 'dated_on_or_before_exclusion' END AS timing,\n count(DISTINCT op.recipient_npi) AS providers,\n count(*) AS payment_records,\n round(sum(op.total_amount_usd), 2) AS total_usd\nFROM public.cms_open_payments op\nJOIN excl e ON op.recipient_npi = e.npi\nGROUP BY 1\nORDER BY total_usd DESC;\n-- timing providers records total_usd\n-- dated_on_or_before_exclusion 118 2,199 3,625,463.77\n-- dated_after_exclusion 181 855 209,757.61\n\n-- 6) MATCHABLE DENOMINATOR — LEIE rows with vs. without an NPI. The 61,030 rows\n-- with no NPI are unmatchable to Open Payments by identifier and are reported\n-- separately, never matched by name.\nSELECT\n count(*) AS total_rows, -- 68,055\n count(*) FILTER (WHERE nullif(btrim(npi), '') IS NOT NULL) AS rows_with_npi, -- 7,025\n count(*) FILTER (WHERE nullif(btrim(npi), '') IS NULL) AS rows_no_npi, -- 61,030\n count(DISTINCT btrim(npi)) FILTER (WHERE nullif(btrim(npi),'') IS NOT NULL)\n AS distinct_npi -- 6,880\nFROM public.oig_leie_exclusions;\n-- total_rows rows_with_npi rows_no_npi distinct_npi\n-- 68,055 7,025 61,030 6,880\n-- matched / matchable = 294 / 6,880 = 4.3% of NPI-identified excluded providers.", "license": "U.S. Government Works (federal sources; 17 U.S.C. §105)", "generated_by": "Fonteum — https://fonteum.com", "notes": "Aggregate, source-traced figures frozen to the snapshot above. Reproduce by running reproducible_sql against the cited federal dataset; no per-entity records are included." }