Pharma Payments to Physicians by State: How to Read the 2025 CMS Data
A state comparison of pharmaceutical-company payments to physicians needs a consistent payment year, recipient population, company definition, and geographic rule. CMS Open Payments provides the underlying disclosures, but its national general-payment total is not a state ranking. This guide explains how to compare states without confusing payment volume with payments per physician or where care occurred.
The focus is Program Year 2025 general payments, made during January through December 2025 and published in 2026. No calculated state league table is presented here. The purpose is to help healthcare analysts evaluate a state comparison and understand what its numbers would mean.
Table of contents
- Define the comparison before reading the totals
- Use the recipient address to assign a state
- Decide which companies qualify
- Compare total dollars and payments per physician
- Keep the calculation consistent
- Use state results to ask better questions
- Frequently asked questions
- Sources
Define the comparison before reading the totals
CMS reports $3.92 billion in general payments for Program Year 2025. That total spans the program's reporting entities and covered-recipient types. It is not a pharmaceutical-company-only total for physicians, so it cannot supply the denominator for a narrower state comparison.
General payments are transfers of value outside a research agreement or protocol. Research payments and ownership or investment interests are separate categories. A physician-focused comparison also needs to exclude teaching hospitals and nonphysician practitioners rather than treat every covered recipient as a doctor.
A clear scope statement would read:
Compare reported 2025 general-payment dollars from qualifying pharmaceutical manufacturers to physician recipients whose reported primary practice or business address is in one of the 50 states. Report Washington, DC separately.
That is a proposed analytical scope, not a result. It makes the population explicit before anyone interprets the order of states.
Use the recipient address to assign a state
The relevant geography is the recipient's primary practice or business state as reported in the selected payment release. It is not the manufacturer's headquarters, the physician's licensing state, the patient's residence, or necessarily the location where care occurred.
For a 50-state comparison, keep DC separate and account separately for territories, foreign addresses, and missing or invalid state values. Do not silently replace a reported address with a current registry address: that changes the geographic definition and may introduce information from a different period.
This distinction matters when a company operates nationally or a physician has several licenses. A manufacturer's home state does not determine where all its physician payments belong, and a license does not establish the practice address attached to a payment.
Decide which companies qualify
Open Payments reporting entities include manufacturers of different covered products and group purchasing organizations. A reporting entity is therefore not automatically a pharmaceutical company.
For a company-based comparison, an analyst could include reporting entities with documented drug or biological-product manufacturing activity during the period and exclude device-only and GPO-only entities. Record the evidence and classification rule for each company. A familiar brand name alone is not enough.
Mixed drug-and-device companies need an explicit decision. Including all their eligible physician general payments produces a company-based measure that can include device-related and product-unspecified payments. Restricting the analysis to records associated with drugs or biological products produces a different, product-associated measure. Use the same choice in every state and name it in the results.
Neither choice justifies allocating one payment in full to every product named on its record. Multiple product associations do not create multiple payment amounts.
Compare total dollars and payments per physician
Different measures answer different questions:
| Measure | Question answered | Interpretation limit |
|---|---|---|
| Total eligible dollars | Where is the largest reported dollar volume? | Affected by the size and composition of the physician population |
| Share of eligible 50-state dollars | What portion of the defined national state total belongs to this state? | Requires the same filters in numerator and denominator |
| Distinct eligible physician recipients | How many individual physicians are represented? | Not the entire physician workforce |
| Dollars per eligible physician recipient | How much was reported per represented physician on average? | Can be strongly affected by a few large payments |
Hypothetical example: State A has $10 million across 2,000 physician recipients; State B has $8 million across 1,000. A has the larger total, but the averages are $5,000 and $8,000 respectively. Neither result identifies an actual state or establishes which state's typical physician received more. A median would require recipient-level totals.
Counts of distinct physicians should be calculated within each state using a validated identifier. A person represented in more than one state can enter more than one state count; adding state counts does not necessarily produce a national count of unique people.
Keep the calculation consistent
Use one publication snapshot for the selected year, apply the same recipient and company rules, and count each eligible payment record once. Do not stack successive refreshes as if they were additional payments.
For state shares, divide each state's eligible dollars by eligible dollars across the same 50-state population. Keep the values for DC and other excluded locations separate from that denominator. Disclose missing geography and identifiers so readers can judge coverage.
Rank exact dollar totals before rounding for display. If equal totals share a rank, state that rule and explain how ties at the cutoff are displayed. A table should also identify its payment year and source release; a recent webpage update is not a new year of payments.
Use state results to ask better questions
A high total can prompt useful questions about the number of physician recipients, the mix of payment categories, or concentration among a small number of recipients. It does not by itself show unusually high payments to the average physician.
State payment totals do not measure clinical quality, prescribing influence, or misconduct. They also do not show where a particular medical service took place.
To examine a comparison, start with the CMS Open Payments search and exploration tools. Check the payment year, recipient type, company scope, and geographic rule before comparing figures. A chart missing those definitions may be describing a different population from the one its headline suggests.
Frequently asked questions
Does the $3.92 billion figure show pharmaceutical payments to physicians?
No. It is CMS's program-wide general-payment total for 2025, across a broader set of reporting entities and covered recipients.
Can a state total be described as payments per physician?
Only after dividing by a stated, matching physician denominator. An average among recipients is different from an average across all physicians practicing in the state.
Does the state identify where treatment occurred?
No. The payment record's recipient-state field concerns the recipient's reported practice or business address.