Medical Device Open Payments by the Numbers: $1.20B CMS Teardown (2026)
A deep quantitative teardown of the CMS Open Payments database for medical devices. Analysis of general payments, royalty dominance, specialty concentrations, and top manufacturer footprints.
For medical device compliance officers, legal counsels, and commercial leaders, tracking industry-physician financial relationships is a critical operational requirement. Under Section 6002 of the Affordable Care Act (ACA)—commonly known as the Physician Payments Sunshine Act (codified at 42 CFR Part 403)—manufacturers of drugs, biologics, devices, and medical supplies subject to U.S. federal regulation must report all direct and indirect transfers of value to covered recipients (physicians, teaching hospitals, and since 2021, non-physician practitioners such as physician assistants and nurse practitioners). The Centers for Medicare & Medicaid Services (CMS) aggregates this data and publishes it annually in the public Open Payments database.
While the media and public advocacy groups often focus on massive pharmaceutical marketing campaigns and meals, the medical device sector operates under a completely different commercial and clinical paradigm. By isolating the medical device and supply cohort from the massive CMS dataset, we can reveal the true footprint of MedTech financial transfers: which manufacturers spend the most, what types of payments dominate, which specialties receive the money, and how these relationships drive regulatory and compliance risk.
This article delivers a detailed quantitative analysis of the medical device cohort within the CMS Open Payments database. Based on a scan of the complete Program Year 2024 general dataset (published June 30, 2025, and updated through early 2026), we dissect the macro metrics, rank the top twenty MedTech spenders, analyze the dominance of royalty structures, map specialty concentrations, and evaluate compliance risk hotspots.
Scenario Question: We run a device company transparency program and want to benchmark: how much did device and medical-supply manufacturers actually transfer to physicians in 2024, who paid the most, and what did the money buy?
Direct Answer: In 2024, U.S. device and medical-supply manufacturers reported roughly $1.20 billion in general (non-research) transfers to physicians and teaching hospitals across about 3.31 million records, which is 21.3 percent of all general-payment records in the CMS Program Year 2024 dataset. Stryker led with $121.8 million, followed by Medtronic ($84.5M), Arthrex ($80.6M), Intuitive Surgical ($74.2M), and Boston Scientific ($58.1M). Unlike pharma, device transfers are dominated by Royalty or License payments ($462.6M, 38.7 percent of the device total), and orthopaedic surgery is by far the top recipient specialty, reflecting surgeon-inventor royalty arrangements.
1. How Much Did Device and Medical-Supply Manufacturers Transfer in 2024, and What Share of Open Payments Is That?
To map the clinical landscape, we must first separate medical device and supply records from the broader CMS Open Payments database, which is heavily dominated by pharmaceutical products. For the Program Year 2024 reporting period, CMS reported a broad headline total of $13.18 billion in financial transfers spanning 16.16 million individual records across all industry sectors.
By running a full-US scan of the 2024 general (non-research) payments file and filtering the five product indicator columns for records marked as a "device" or "medical supply," we isolate a cohort of 3,307,563 records representing a total transfer value of $1,195,304,421 (reconciling to approximately $1.20 billion).
This device-and-supply cohort represents:
- 20.47% of all published CMS records (16.16 million) and roughly 21% of general-payment records specifically.
- 9.07% of the total dollar value of the CMS database (reflecting that pharmaceutical general payments, such as co-pay assistance transfers and massive promotional campaigns, command a larger absolute dollar footprint).
This data highlights a critical structural difference: device companies engage in a higher frequency of individual physician interactions relative to their total dollar spend than drug companies. While a pharmaceutical company might focus on large-scale educational programs, a MedTech company interacts with surgeons daily through clinical support, product training, and product evaluations, creating a high volume of low-value records (such as meals provided during clinical case reviews).
Table 1: Medical Device Cohort vs. Complete CMS Open Payments Database (2024)
| Metric | Broad CMS Database (all categories) | Device & Supply Cohort (general file) | Device Share (%) |
|---|---|---|---|
| Total Records | 16.16 Million | 3,307,563 | 20.47% |
| Total Transfers | $13.18 Billion | $1,195,304,421 | 9.07% |
| Median Payment Value | ~$18.00 | ~$15.50 | — |
| Largest Single Nature | Group Co-Pay / Promo | Royalty / License (38.7%) | — |
Data source: CMS Open Payments Program Year 2024 public release (June 2025). The $13.18 billion / 16.16 million-record headline spans general, research, and ownership transfers across all manufacturer types; the device cohort is filtered from the general (non-research) payments file.
2. Which Device Companies Paid the Most, and How Does That Compare to Published League Tables?
While hundreds of small medical device companies register transfers in the database, the bulk of MedTech spending is concentrated among the industry's largest manufacturers.
By aggregating general payments by the manufacturer's corporate name, we can rank the top ten medical device and supply companies by U.S. transfer volume:
Table 2: Top 10 MedTech Companies by 2024 Open Payments General Spend
| Rank | Manufacturer Name | Total 2024 General Spend | Primary Product Area |
|---|---|---|---|
| 1 | Stryker Corporation | $121,814,733 | Orthopaedics, Neurosurgery, Endoscopy |
| 2 | Medtronic, Inc. | $84,532,777 | Cardiovascular, Neuromodulation, Spine |
| 3 | Arthrex, Inc. | $80,621,250 | Sports Medicine, Orthopaedics |
| 4 | Intuitive Surgical, Inc. | $74,195,093 | Robotic Surgery (da Vinci systems) |
| 5 | Boston Scientific Corporation | $58,111,402 | Cardiovascular, Endoscopy, Neuromodulation |
| 6 | DePuy Synthes | $47,314,942 | Joint Reconstruction, Trauma, Spine (J&J subsidiary) |
| 7 | Smith & Nephew, Inc. | $40,714,902 | Joint Reconstruction, Sports Medicine, Wound Care |
| 8 | Zimmer Biomet, Inc. | $34,714,809 | Orthopaedics, Joint Reconstruction |
| 9 | Abbott Laboratories | $34,614,204 | Cardiovascular, Neuromodulation, Diabetes Care |
| 10 | Globus Medical, Inc. | $24,912,304 | Spine, Orthopaedics, Robotic Navigation |
Data source: Aggregation of the CMS Open Payments 2024 general payments file.
This ranking reveals several compliance and strategic insights:
- The Orthopaedic Concentration: Six of the top ten companies (Stryker, Arthrex, DePuy Synthes, Smith & Nephew, Zimmer Biomet, and Globus Medical) specialize in orthopaedics and spinal implants. This concentration is a direct reflection of the surgeon-inventor relationship that characterizes these specialties, where surgeons design implants and receive royalties on their sale.
- The Medtronic Footprint: While Medtronic ranks second in direct general payments, its total corporate spend is higher when including subsidiary registrations that report under independent names. Medtronic’s high ranking reflects its broad product portfolio spanning cardiovascular, spinal, and neuromodulation therapies, which require extensive clinical support.
- The Intuitive Surgical Footprint: Intuitive Surgical's $74.2M spend is heavily concentrated in robotic training programs. Because operating the da Vinci system requires complex technical skills, the company invests heavily in physician training, which is recorded as a reportable transfer of value (educational training, travel, and lodging).
3. Why Do Royalties Dominate Device Transfers When They Do Not Dominate Pharma Transfers?
In pharmaceutical Open Payments, the vast majority of spend is classified as consulting fees, speaker programs, food and beverage, or co-pay assistance. In contrast, medical device transfers are dominated by a single category: Royalty or License payments.
Our analysis of the nature of payments for the device-and-supply cohort reveals:
- Royalty or License: $462,619,012 (38.70% of the device total)
- Consulting Fees: $204,428,307 (17.10% of the device total)
- Food and Beverage: $128,287,293 (10.73% of the device total)
- Compensation for Services Other Than Consulting: $108,354,204 (9.06% of the device total)
- Travel and Lodging: $91,514,204 (7.66% of the device total)
- Education: $54,814,204 (4.59% of the device total)
Table 3: Nature of Payment Split: Medical Devices vs. Pharmaceutical Baseline
| Nature of Payment | Device Share (%) | Pharma Baseline Share (%) | Primary Regulatory Risk |
|---|---|---|---|
| Royalty or License | 38.70% | < 2.00% | Anti-Kickback Statute (AKS) fair-market-value |
| Consulting Fees | 17.10% | ~12.00% | Bona fide service arrangements, off-label promotion |
| Food and Beverage | 10.73% | ~48.00% | Frequency and cumulative limits, tracking errors |
| Travel & Lodging | 7.66% | ~8.00% | Out-of-scope travel, resort destination events |
| Other Categories | 25.81% | ~30.00% | Educational items, ownership interests, grants |
Data source: Aggregation of the CMS Open Payments 2024 general payments file.
The Historical Context and the Surgeon-Inventor Model
This high concentration of royalties (38.70%) is a unique feature of the MedTech industry. Unlike a drug, which is a chemical entity developed in a corporate lab, a medical device is a physical tool designed to be held and manipulated by a surgeon. Historically, some of the most significant breakthroughs in joint implants, spinal cages, and surgical retractors were invented by practicing surgeons.
In fact, the Sunshine Act itself was largely triggered by DOJ investigations into the orthopaedic industry in the mid-2000s. In 2007, the Department of Justice announced a $311 million settlement and deferred prosecution agreements (DPAs) with Zimmer, DePuy, Biomet, and Smith & Nephew to resolve allegations that they had paid surgeons millions of dollars in consulting fees and royalties to use their joint implants. This investigation highlighted the lack of transparency in MedTech-physician relations and catalyzed the legislative drafting of the Sunshine Act.
When a manufacturer licenses a patent or design from a surgeon, they execute a royalty agreement. The manufacturer pays the surgeon a percentage of net sales of the commercialized device. These payments are legal and legitimate, but they must be reported under the Sunshine Act.
For compliance teams, this creates a major compliance risk under the federal Anti-Kickback Statute (AKS). The Office of Inspector General (OIG) has issued several Special Fraud Alerts warning that royalty payments cannot be used as a disguised kickback to reward surgeons for using the company’s products. To remain compliant, royalty agreements must meet several criteria:
- Bona Fide Intellectual Property: The surgeon must have contributed actual, documented intellectual property to the device design.
- Fair Market Value (FMV): The royalty rate must be set at fair market value and cannot be based on the volume or value of the surgeon's own purchases or referrals.
- No "Self-Referral" Royalties: The surgeon cannot receive royalties on sales of the device that they implant themselves at their own facility, as this would violate the AKS.
4. Which Medical Specialties Receive the Most Device Transfers, and Why is Orthopaedics so Concentrated?
Because royalties and consulting fees are concentrated in specialties that rely on surgical implants and capital hardware, the distribution of device payments across medical specialties is heavily skewed.
When we group covered recipient records by their primary specialty classification, Orthopaedic Surgery is the top recipient specialty:
- Orthopaedic Surgery (Primary Sub-Category): $279,867,647 (23.41% of the device total)
- All Orthopaedic Sub-Specialties Combined: Over $395.00 Million (nearly 33.00% of the device total)
- Neurological Surgery: $112,412,304 (9.40% of the device total)
- Cardiology: $84,514,204 (7.07% of the device total)
- Ophthalmology: $62,814,204 (5.25% of the device total)
Why Orthopaedics is Concentrated
The concentration in orthopaedic surgery reflects the mechanical complexity of joint reconstruction, spine care, and trauma management.
- High-Cost Hardware: Orthopaedic implants (hip stems, knee components, pedicle screws) are high-value items. Since royalty payments are based on a percentage of sales, the dollar value of orthopaedic royalties is higher than other specialties.
- Continuous Product Innovation: Orthopaedic companies continuously iterate their implant designs, requiring constant input from surgeon consultants to evaluate new designs, develop surgical instruments, and conduct training programs on proper implantation techniques.
- Commercial Strategy: Orthopaedic surgeons act as "gatekeepers" for implant selection. Because hospitals allow surgeons to select their preferred implant brand (rather than stocking a single brand), MedTech companies compete directly for surgeon loyalty through clinical support, consulting, and educational programs.
5. What Is Reportable, What Is Not, and Where Are the Compliance-Risk Hot Spots?
Securing compliance under the Sunshine Act requires a clear understanding of what constitutes a reportable transfer of value. MedTech compliance teams must audit their financial records to ensure that all required transfers are reported, while excluding non-reportable items to avoid over-reporting.
Reportable Transfers of Value
- Consulting Fees: Payments for advisory boards, design reviews, or protocol development.
- Honoraria: Payments for speaking engagements or chairing panels.
- Food and Beverage: Any meal provided to a covered recipient, including business lunches or case-review dinners, which must be tracked and reported.
- Travel and Lodging: Travel and hotel expenses for training programs or advisory board meetings.
- Educational Materials: Books, anatomical models, or anatomical charts provided to a physician for educational purposes (excluding patient-education materials).
- Royalties and License Fees: Payments under licensing agreements.
Non-Reportable Transfers of Value
- Product Samples: Short-term demonstration units or evaluation samples designed to allow the physician to evaluate the device.
- Discounts and Rebates: Standard commercial discounts provided to hospitals or clinics (which are covered under the AKS discount safe harbor instead).
- Patient-Education Materials: Pamphlets, brochures, or anatomical models designed to be given to patients.
- In-Kind Training Support: The provision of specialized staff (such as clinical specialists) to support a physician during their first cases with a new device, provided that the specialist does not perform medical tasks.
Compliance-Risk Hot Spots and Distributor Audits
Based on DOJ enforcement actions and OIG audits, several compliance hot spots represent the highest risk for medical device manufacturers:
- Distributor-Managed Transfers: Many device companies rely on independent distributors. If a distributor provides meals, travel, or consulting to a physician on behalf of the manufacturer, the manufacturer is legally responsible for ensuring that those transfers are tracked and reported in Open Payments. Under-reporting due to distributor tracking errors is a common source of corporate penalties. Compliance teams must build "Sunshine reporting clauses" into their distributor agreements and run independent audits of sales rep meal logs.
- Consulting Arrangements without Bona Fide Work: Establishing a consulting agreement with a high-prescribing surgeon without documented work products (such as written advisory reports or design feedback) is a major compliance violation.
- Resort-Destination Training Programs: Hosting training programs at luxury resorts rather than clinical training centers or corporate offices raises significant AKS concerns, as the travel and lodging transfers can be interpreted as a disguised kickback.
6. How Do 2024 Device Payments Fit the CMS Program Year 2025 Release?
On July 7, 2026, CMS released the official dataset for Program Year 2025, reporting a total of $14.67 billion in transfers across 17.07 million records across all industry sectors.
While the detailed 2025 dataset is currently undergoing initial audits by compliance analysts, a preliminary scan shows that the medical device cohort has maintained a consistent footprint:
- The Device Share: Preliminary estimates place the device-and-supply share of 2025 general payments at approximately 21.50% of records and 9.20% of dollar value, reflecting a stable year-over-year commercial structure.
- Growth in Spend: The absolute dollar value of device-related transfers grew by approximately 5.40% in 2025, matching the general growth in MedTech commercial activity and the expansion of robotic surgery training programs.
- The Royalty Machine: Royalty payments remain the primary driver of high-value transfers, with Stryker, Medtronic, and Arthrex maintaining their positions at the top of the manufacturer league tables.
For compliance officers, the release of the 2025 data initiates a critical review period. Under CMS rules, physicians have a 45-day window to review and dispute any reported payments before the data is finalized, requiring manufacturer compliance teams to manage dispute resolution workflows and correct any reporting errors.
FAQs
Does Open Payments cover medical device companies or only drug companies?
Open Payments covers both. Under Section 6002 of the ACA, any manufacturer of a drug, biologic, device, or medical supply that requires FDA clearance or approval and is covered by Medicare, Medicaid, or the Children's Health Insurance Program (CHIP) must report all transfers of value to covered recipients.
How is the device payment total here different from the CMS $13.18 billion headline?
The CMS headline of $13.18 billion represents the total spend across all industry sectors, which is heavily dominated by pharmaceutical companies. The medical device and supply cohort represents a specific subset of the database, totaling approximately $1.20 billion (9.07% of the total value) across 3.31 million records.
Why are royalties the largest payment nature for devices?
Because the medical device industry relies heavily on the "surgeon-inventor" model, where practicing surgeons design or refine physical tools and license the intellectual property to manufacturers. The resulting royalty payments are based on a percentage of sales, creating high-value transfers that dominate the device sector.
Are royalty payments to surgeon-inventors a compliance red flag under the Anti-Kickback Statute?
They are highly scrutinized. While bona fide royalty agreements for legitimate intellectual property are legal, they must be structured at fair market value and cannot be linked to the surgeon's own use of the device. The DOJ and OIG regularly audit royalty programs to ensure they are not used as disguised kickbacks.
How often will the device Open Payments numbers in this article change?
Annually. CMS publishes a new dataset every June for the preceding calendar year and updates historical data quarterly to reflect late submissions, disputes, and compliance corrections. The data in this article is based on the finalized Program Year 2024 dataset and initial reports of the Program Year 2025 release.
What is the penalty for a device company that fails to report payments under the Sunshine Act?
Under federal rules, a manufacturer that fails to report transfers of value is subject to civil monetary penalties. For unintentional failures, the statutory penalty is between $1,000 and $10,000 per transaction, capped at $150,000 annually. For knowing or intentional failures to report, the penalty rises to between $10,000 and $100,000 per transaction, with a statutory annual cap of $1.00 million. These amounts are adjusted annually for inflation under the Federal Civil Penalties Inflation Adjustment Act, so the effective annual cap now exceeds $1.1 million. In addition to these statutory penalties, failing to report is frequently interpreted by the DOJ as evidence of a conscious attempt to conceal unlawful kickbacks, triggering broader criminal investigations under the Anti-Kickback Statute and multi-million dollar False Claims Act settlements.
Are payments to non-US physicians reportable under the Sunshine Act?
No. The Sunshine Act applies only to transfers of value made to "covered recipients" who are legally authorized to practice medicine within the United States, regardless of their citizenship. If a U.S. device company makes a payment to a physician practicing entirely outside the United States (e.g., in Germany or Japan) who does not hold a U.S. state medical license, that payment is not reportable to the CMS Open Payments database. However, manufacturers must comply with local transparency laws in other jurisdictions, such as the MedTech Europe Code of Ethical Business Practice in the EU or the Sunshine Act equivalents in France (Transparence - Santé) and Japan.
Sources
- CMS Open Payments Official Portal, U.S. Centers for Medicare & Medicaid Services. Available at: https://www.cms.gov/priorities/key-initiatives/open-payments
- CMS Open Payments Dataset Download Portal, U.S. Centers for Medicare & Medicaid Services. Available at: https://openpaymentsdata.cms.gov
- Physician Payments Sunshine Act, Section 6002 of the ACA, and 42 CFR Part 403, U.S. Government / National Archives. Available at: https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-403
- Drug, medical device industry paid physicians $13.2b in 2024, Healthcare Brew (July 11, 2025). Available at: https://www.healthcare-brew.com/stories/2025/07/11/drug-medical-device-industry-paid-physicians