AstraZeneca knows that to make a meaningful difference to patient health, it is important to be open about how we conduct our business. We are committed to the highest standards of conduct in all of our operations, including how we partner with physicians and medical institutions.
We partner and collaborate with physicians and institutions in efforts to educate the healthcare community and to conduct scientific and medical research. Patients ultimately benefit when physicians are well informed and knowledgeable about our medicines. AstraZeneca reports information on payments and transfers of value to US-based physicians and teaching hospitals for all phases of research and development, consulting fees, speaker fees, modest meals and travel in association with contracted services or in conjunction with a product or informational discussion, educational items, royalties, license fees, and ownership or investment interests. We include both direct payments to physicians, as well as payments made to entities related to a physician at the request of, or on behalf of, that physician. In addition, our reports include certain payments to physicians made through third-party entities, such as medical education providers and clinical research organizations, on behalf of AstraZeneca.
AstraZeneca’s external transparency reporting meets the requirements of the Physician Payments Sunshine Act (Open Payments), which went into effect on August 1, 2013, as well as relevant state transparency laws.
Frequently Asked Questions
What types of payments and transfers of value are being reported under Open Payments?
Direct and indirect payments and transfers of value to US-licensed physicians and US teaching hospitals, including:
· Compensation for speaking, advisory board and consulting services
· Meals and reimbursed expenses for travel and lodging
· Items of value (e.g., textbooks, journal reprints) and
· Investigator fees and study supplies
Certain items such as samples (including vouchers and coupons) and patient educational materials are excluded from Open Payments reporting, although they may be reported to certain states to meet specific state reporting requirements.
Payments and transfers of value made directly or indirectly by AstraZeneca’s US business, including Acerta, are included in the reports on this site. Payments and transfers of value made by certain non-US AstraZeneca entities are also included in the Open Payments reports submitted to CMS (Centers for Medicare & Medicaid Services), the Federal government agency responsible for implementing the Physician Payments Sunshine Act.
Who is included in these reports?
We are reporting payments and transfers of value to US-based physicians and related entities. This includes both direct payments to physicians as well as payments made to entities related to a physician at the request of, on behalf of, or for the benefit of, that physician. The reporting will also capture certain indirect payments to physicians made through third-party entities, such as clinical research organizations.
We are also reporting payments and transfers of value to US-based medical and research institutions, hospitals, clinics and group practices for all phases of research and development. This includes both direct payments and indirect payments through a contract research organization or academic research organization.
How frequently will payment data be updated?
CMS will update the Open Payments reports on at least an annual basis, with occasional non-scheduled data refreshes to be determined by CMS.
How are physician speakers or consultants identified?
Physicians are selected to consult or speak about AstraZeneca and our medicines based on expertise in a therapeutic area, experience and qualifications. Speakers are required to complete regulatory, compliance and product training, as appropriate.
Does hiring physicians to consult or speak about AstraZeneca products increase the cost of medicines and ultimately healthcare?
No. AstraZeneca believes that patients ultimately benefit and costs are reduced when physicians are well informed and knowledgeable about our medicines and treatment options. Physicians are also indispensable partners in our efforts to bring new medicines to patients. This partnership takes many forms, including clinical trials to investigate the safety and efficacy of potential new medicines and providing us with guidance that allows us to better understand treatment challenges and unmet medical needs.
Is there a minimum amount of value for a payment or transfer of value to be reported?
There are specific key (de minimis) thresholds for reporting. The Open Payments key (de minimis) thresholds for reporting are adjusted annually based on the consumer price index.
Why are the expenses for amounts less than $10 included in the Open Payments reports?
Payments or other transfers of value that are less than the minimum amount are excluded unless the amount of all payments in the reporting year exceed the aggregated total that is adjusted annually based on the consumer price index.
Does AstraZeneca reimburse for expenses?
Yes. AstraZeneca reimburses physicians for reasonable meal and travel expenses incurred in association with speaker, consulting or research services.
How does AstraZeneca ensure the data is accurate?
The information posted is the result of our good faith efforts to capture and present information on payments and items of value accurately. Because of the breadth of the data and the complexity of the processes and systems required to collect it, the possibility of errors and omissions cannot be eliminated. AstraZeneca conducts a comprehensive review of the data included in the reports prior to posting. In the event of identified omissions or discrepancies, the data will be corrected in subsequent reports.
How does AstraZeneca report the value of meals provided to physician offices?
Meals may be provided to healthcare professionals for the purposes of engaging in discussions to share product and disease related information with physicians and their staff. AstraZeneca will submit to CMS the per person value of any meal in which a physician participates. The value of meals provided is determined by dividing the total cost of the meal by the total number of participants of the meal. Participants may include physicians, medical staff, and AstraZeneca representatives.
Are there any tax implications related to these reporting requirements?
Please consult with your tax advisor regarding any questions related to tax implications.
I was a principal investigator for an AstraZeneca study and did not receive any direct payments for the study since my institution was paid. Why is my name appearing in the Open Payments reports for these study payments?
Open Payments requires that all manufacturers identify the Principal Investigators in connection with research payments made to the institutions. Please note that for the CMS Research report, inclusion of the Investigator name does not reflect, nor is it intended to imply, that any of the funds went to the listed Principal Investigator. The institution receiving the funds is indicated in the Open Payments report.
What can physicians and teaching hospitals do to dispute what was reported to CMS for Open Payments?
Physicians and teaching hospitals can dispute data through the defined CMS review and dispute process on the CMS website. Note that physicians and teaching hospitals must have first successfully registered in both the Enterprise Identity Management System and have requested and received access to the Open Payments system prior to reviewing data and submitting a dispute in the Open Payments system. AstraZeneca will be notified by CMS of the details of their dispute and will be able to review the dispute only after CMS receives the dispute.
What do physicians and teaching hospitals need to do to preview or dispute payments or transfers of value submitted under Open Payments?
Physicians and teaching hospitals must register in CMS’ Enterprise Portal (Enterprise Identification Management system – EIDM) and the Open Payments system in order to preview any data submitted to CMS prior to the data being made public. CMS publishes data preview windows approximately 60-90 days in advance of the data publication deadline. Registration in EIDM is required for access to the Open Payments system (some physicians and teaching hospitals may already have an EIDM account). Registration is a voluntary process, but it is required for physicians and teaching hospitals to review or dispute Open Payments data.
What is the timing to submit disputes for Open Payments?
The Open Payments review, dispute and correction process is open intermittently approximately 60-90 days prior to the data publication date and is published by CMS. The 45-day preview period is for physicians and teaching hospitals to review and initiate any disputes they may have regarding the data reported about them. Disputes submitted after the preview period may not be corrected and re-published until after the next review and dispute window, which will be scheduled at the discretion of CMS.
Can AstraZeneca change the information reported about physicians or teaching hospitals on the CMS website for Open Payments?
No. Manufacturers cannot change the data unless the CMS defined Dispute and Resolution process is followed and/or an error was found in the data. AstraZeneca conducts a comprehensive review of the data in the reports to ensure accuracy prior to posting. All changes to data submitted to CMS are subject to a CMS publication and data refresh schedule, including availability for preview and dispute prior to publication.
How might I find additional information about Open Payments?
To learn more about the National Physician Payment Transparency Program (Open Payments), please visit the CMS site at:
For guidance on how to complete the registration process, please refer to this step-by-step process:
There is additional information for Physicians and teaching hospitals on how to Review & Dispute Open Payments at:
Physicians and teaching Hospitals can submit questions via email to the CMS Help Desk at firstname.lastname@example.org.
Live CMS Help Desk support is also available by calling 1-855-326-8366, Monday through Friday, from 7:30 a.m. to 6:30 p.m. (CT), excluding Federal holidays. The American Medical Association also has provided information about Open Payments for physicians at the following sites:
What is included in the Nature of Payment categories under Open Payments?
AstraZeneca includes the following in each of the defined categories by CMS in the Open Payments reports:
|CMS “Nature of Payment” Reporting Category||What is included?|
|Consulting fees||Payments to physicians or to entities on the behalf of physicians for consulting services, advisory boards, or training of company employees|
|Compensation for services other than consulting, including serving as faculty or as a speaker at an event other than a continuing education program||Speaking fees paid by the company, medical writing/editorial services provided to support publications, any other fee paid to a physician or teaching hospital as compensation for services provided, membership fees, or logistical program fees|
|Honoraria||AstraZeneca does not pay Honoraria, thus this category is not used by AstraZeneca|
|Gifts||Donations, sponsorships, contributions, or in-kind support provided to non 501(c)3 organizations|
|Entertainment||AstraZeneca does not provide Entertainment, thus this category is not used by AstraZeneca|
|Food and beverage||All food and beverage provided to facilitate product discussions, during speaker programs, or while speakers or consultants are providing services. May be provided directly or reimbursed by the company.|
|Travel and lodging||Airfare/train, lodging, or reimbursable mileage provided to speakers or consultants to travel to and from event locations|
|Education||Educational items provided to physicians such as textbook or journal reprints|
|Research||Study fees, study drug, and study supplies provided to research study sites to fund or support clinical or pre-clinical research studies|
|Charitable contributions||Contributions, donations, or sponsorships made directly or indirectly to teaching hospitals that are also 501(c)3 organizations|
|Royalty or license||Payments to physicians or teaching hospitals that are fees or royalties for a licensing agreement|
|Current or prospective ownership or investment interest||AstraZeneca does not make payments in the form of prospective ownership or investment interest, thus this category is not used by AstraZeneca|
|Compensation for serving as faculty or as a speaker for an unaccredited and non-certified continuing education program||Speaking fees for non-accredited independent education programs paid by third parties such as medical education providers where AstraZeneca provided an independent educational grant to the third party to assist with funding for the educational program|
|Grants||Independent grants provided to teaching hospitals for the purposes of funding medical education; scholarships or fellowships, research or investigator awards|
|Space rental or facility fees (teaching hospitals only)||Payments to teaching hospitals to rent meeting rooms for educational programs and exhibit fees|