Written by Anonymous Excel Guy
I am about to argue that I should be put out of a job.
My day-to-day job consists of collecting, validating, and ultimately reporting financial interactions between medical manufacturers and healthcare professionals to the US federal government for compliance with the Sunshine Act. In my position, most of my time is spent scrolling through thousands of rows of data in hopes of finding minor errors that, if not corrected, could lead to large financial penalties.
Here’s what this looks like in practice. When healthcare professionals attend an industry-sponsored event, nearly everyone has a flight, hotel room, meals, and ground transportation. A meeting planner might inadvertently allocate a hotel charge to the wrong attendee or divide room expenses incorrectly. That’s where I come in. I analyze the data, make corrections for reporting, and communicate back to the meeting planners, who surely have much more important things on their mind than remembering the Sunshine Act. It’s tedious but necessary. An allocation error can create compliance exposure, so we spend considerable time making sure every dollar ends up in the right spreadsheet cell.
This is the kind of work that keeps people like me employed. And I don’t think it’s making healthcare any better.
Did you know there’s a website where you can look up your family’s doctors and see what kinds of financial relationships they have with the medical industry? Every consulting payment, every royalty payout, and every reportable meal paid for by a pharmaceutical company is meticulously published on an annual basis. If you didn’t know, you’re not alone. In my estimation, not only do most Americans not know this program exists, most doctors don’t remember it does either. It’s called the Open Payments program, and it is run by the Centers for Medicare & Medicaid Services (CMS).
The program was established by the Sunshine Act, passed in 2010 as part of the Affordable Care Act. Championed by Republican Senator Chuck Grassley, it launched in 2013. Since then, pharmaceutical and medical device companies have had to devote staff and resources to collecting and reporting financial transactions, lest they face potentially significant civil penalties for violating federal law. The intent of the Sunshine Act is noble. Particularly in the wake of the opioid epidemic, it’s reasonable to demand transparency in this space. Relationships between industry and doctors can influence medical decisions. If a doctor is getting paid tens of thousands of dollars by a company that manufactures a drug, how do we know that their prescription for that drug is based on what the patient actually needs?
But the Sunshine Act has three problems. First, it is far too expansive in scope, with mission creep already evident in the expansion of the program in 2021. Second, it imposes substantial burdens on industry without a clear corresponding benefit for patients. Third, while it requires extensive disclosure, it does little by itself to prevent misconduct.
The goal of transparency is good. The problem is a system that demands paperwork for a $25 lunch as well as a $25,000 consulting contract.
It’s Too Expansive
Out of more than 17 million transactions reported for calendar year 2025, almost 15 million were for food and beverage payments alone. Nearly $450 million in food and beverages was reported by 1,435 manufacturers. All the big players are here: Pfizer, Stryker, Eli Lilly. What is this telling us? That physicians across the country are in the pocket of Big Pharma? That the next time you see your primary care physician, you should ask about the $20 meal purchased on their behalf by AstraZeneca?
Anyone familiar with this element of the medical industry understands why it’s a questionable reporting metric. Meals are low in dollar value and high in transaction count. Not only are expensive steak dinners reported, but so are relatively small transactions that cross the applicable reporting thresholds. That’s every qualifying box of donuts brought in by a rep to a surgery center, every Starbucks coffee, every snack at a conference paid for by industry.
Business is conducted over meals, not only in the medical industry but in every industry. If you want to convince medical professionals that your new product is superior to the one they’re currently using, you might do that over food. Training is frequently conducted over meals as well. If your company has just signed a contract with a health system to purchase one of your products, you’ll need seminars to educate its staff. You can bet your employees are bringing in catering. Multiply that annoyance across every hospital and clinic a company serves, then across every manufacturer in the country.
These meal transactions tell us very little. They’re a metric of how much business the medical industry is conducting, not necessarily how much money nefarious otoscope manufacturers are putting into the pockets of doctors they want to undermine. Real compensation — consulting fees, honoraria, royalties — is significantly more meaningful. Those payments show a direct financial relationship between a company and a doctor rather than a minor transfer of value on the doctor’s behalf.
There is evidence that even small industry-sponsored meals can influence prescribing behavior, so the concern shouldn’t be dismissed outright. But that doesn’t establish that the current reporting requirements are proportionate to their benefits. A database containing millions of minor transactions doesn’t necessarily help patients distinguish meaningful conflicts of interest from ordinary business interactions. As of 2026, if a single covered recipient crosses the total $138.13 annual threshold, every single transaction for them is reportable, even if it’s only $1.
The expansion of Open Payments in 2021 also extended the definition of “covered recipient” beyond physicians to include advanced practice registered nurses, physician assistants, and anesthesiologist assistants. Again, the intent is noble. Nurse practitioners can prescribe drugs and often function as primary care providers. But the expansion also covers certified registered nurse anesthetists and anesthesiologist assistants, whose roles differ substantially from those of prescribing physicians. The more categories of professionals and transactions we add, the greater the compliance headache.
It’s Unnecessarily Burdensome
A small medical device company is unlikely to have a dedicated employee for complying with this regulation. Its transaction volume is too low. More likely, it’ll pull someone in accounting who has access to NetSuite and devote a few hours each month to the task. For a large company, entire teams may be dedicated to collecting transactions, cleaning up reportable data, and managing submissions. The penalties for noncompliance can be substantial, and the reputational consequences of an enforcement action can be even more damaging.
What we end up with is a laborious process of diving into one system for airfare payments, another for grants, and a third for consulting contracts. Much of the effort isn’t directed at finding misconduct but at assembling information for reporting.
Of course, every regulation imposes some burden. The question is whether the benefits justify the costs. For much of the Sunshine Act, I believe it does not.
Startups in healthcare are trying to create novel solutions to existing problems. It’s one of the best parts of the American healthcare system, regardless of all its faults, that we have a churn of baby companies trying something new. Threatening them with substantial penalties over administrative minutiae adds another burden to an already complicated regulatory environment.
For large, established companies, this is yet another department in a Byzantine administrative system. They can certainly afford it, but is it worth it? I’m not so concerned about the bottom lines of billion-dollar companies (Lord knows there’s enough bloat in there with or without the Sunshine Act), but I question whether a company manufacturing pacemakers for Americans’ hearts should devote so many resources to tracking relatively minor transactions that could otherwise be used elsewhere.
The Sunshine Act Doesn’t Actually Prevent Misconduct
Open Payments is a transparency program. It doesn’t directly prevent or prohibit financial relationships. Anti-kickback laws are what make it illegal for pharmaceutical companies to enter into certain backroom deals with doctors to prescribe unnecessary drugs in return for hidden payments. Those are the good laws — laws that make it illegal to harm patients who trust their doctors to uphold the Hippocratic oath — and they existed long before the Sunshine Act.
The Sunshine Act requires companies to report financial interactions to the government and publishes them on a website relatively few patients appear to know about. It’s true that investigators, journalists, and researchers can use those disclosures to uncover suspicious relationships. That’s a legitimate benefit, but reporting itself doesn’t prohibit misconduct. Kickbacks were illegal before the Sunshine Act and remain illegal today.
Imagine a sales rep who’s college friends with a surgeon. They conspire to make more money together: The surgeon agrees to overuse the company’s spinal fusion implants, the rep receives a massive sales bonus, and the surgeon secretly gets a cut. The only parties hurt are the patient and Medicare, which pays for an unnecessary procedure. That’s already illegal. Where exactly does Open Payments come into play? Do we really think the surgeon and rep are going to put their arrangement on record?
Sure, disclosure requirements can help investigators uncover suspicious patterns, and the possibility of public scrutiny may deter some questionable relationships. But those benefits have to be weighed against the costs of collecting and publishing millions of transactions that have little connection to misconduct.
If you want fewer inappropriate opioid prescriptions, regulate prescribing directly. If you want harsher penalties for kickbacks, make that change. Instead, we have a system that requires a great deal of reporting without a clear measure of what it accomplishes.
In my experience, many covered recipients don’t even check the transactions reported on their behalf, and many physicians barely remember the Sunshine Act exists. As for patients, how many know they can search for their doctor’s name? I’d be interested to know how many searches come from patients rather than manufacturers checking their own data.
If we’re going to require companies to spend countless hours collecting information, shouldn’t we have a better understanding of who uses that information and what value it provides?
Solutions
We should reform the Sunshine Act. Its expansive nature may be difficult to rein in by excluding particular categories of healthcare professionals, but we can remove mandatory reporting requirements for meals, travel, and lodging. These transactions are often secondary to the underlying financial relationship. If a physician is a consultant under contract, the company may pay for airfare and hotels. Is it the travel and lodging that’s important to report, or the consulting payments themselves?
My first proposal is to make food and beverage, travel, and lodging reporting voluntary. This would retain the infrastructure built by CMS and industry while removing the obligation to track thousands of relatively minor transactions under threat of penalties. Companies that want to stay squeaky clean in the eyes of the public could continue publishing everything. Others could devote their resources to more substantial payments that are less frequent and more revealing of potential conflicts of interest.
A narrower alternative would be to raise reporting thresholds substantially and focus mandatory disclosures on payments large enough to suggest a meaningful financial relationship. Either approach would reduce administrative burdens while preserving transparency where it matters most.
Industry codes of ethics can also complement government oversight. Organizations like AdvaMed and MedTech Europe maintain standards governing relationships between manufacturers and healthcare professionals. These aren't substitutes for enforcing anti-kickback laws, but they demonstrate that transparency and professional accountability need not depend exclusively on exhaustive federal reporting.
My second proposal is to significantly narrow how the Sunshine Act applies to medical device manufacturers. A company that makes insulin pumps for diabetics is simply not the same as a pharmaceutical company. What exactly is the concern when examining the financial relationship between an endocrinologist and companies like Tandem or MiniMed? Are they not supposed to have any? Is a diabetic patient at risk of receiving an unnecessary insulin pump simply because the physician has a relationship with its manufacturer?
Medical device companies can certainly create conflicts of interest, particularly involving implants and surgical equipment. But they also have legitimate reasons to work closely with physicians on training, product development, and technical support.
Rather than treating every interaction as equally suspect, we should consider reporting requirements that distinguish routine training and technical support from substantial financial arrangements that might influence clinical decisions. A surgeon receiving significant consulting payments from an implant manufacturer presents a different potential conflict than a physician attending a training session on a new insulin pump. Our disclosure requirements should reflect that distinction.
Most importantly, I’m not proposing that we get rid of Open Payments entirely. I understand its intent, and I believe the program has some value. The problem isn’t that it exists, but how it exists. Its scope is massive, its burden on companies is substantial, and its benefits are often unclear. If we think it’s inappropriate for industry and physicians to have any financial relationships, we risk strangling medical innovation. If we want to prevent kickbacks and corruption, separate laws already prohibit them. So if the goal is to shine some sunlight on these relationships, what exactly is it we want to see?
I spend my days searching for minor discrepancies in transactions that almost nobody will ever look at. I know firsthand how much work this system requires. What I don’t know is whether it’s making patients any safer. As someone who makes a living helping companies comply with these requirements, I'd welcome reform, even if it means less work for people like me.
Anonymous Excel Guy is a healthcare compliance worker who works for a large American medical device manufacturer writing under a pseudonym.