Federally excluded NPIs receiving industry payments (Open Payments)
Pharmaceutical and device manufacturers report payments to physicians and teaching hospitals under the Sunshine Act. If a manufacturer is paying a federally excluded provider, that is an industry-side compliance gap. **Result: 350 of 8,619 currently-active LEIE/SAM-excluded NPIs received industry payments in PY 2024, totaling \$3.8M.** 9 of those 350 are VA-resident per NDH. One NPI (FRANK, ALEXANDER, OK) alone accounts for \$3.08M.
Headline
350 of 8,619 currently-active LEIE / SAM-excluded NPIs received industry payments from drug and device manufacturers in program year 2024 per CMS Open Payments. Combined paid amount: $3,826,596. Of those 350 matches, **198 were paid STRICTLY POST-EXCLUSION** (earliest LEIE/SAM exclusion year before 2024), with $166,984 in strict post-exclusion industry payments. 9 of the 350 matches are VA-resident per NDH; 2 of those VA-resident matches are also strict post-exclusion. The strict-post-exclusion subset is the regulatorily significant signal — pre-exclusion industry payments reflect work the provider was authorized to do at the time.
198 / 8.6K = 2.30%
unit: count
Null hypothesis
Zero LEIE/SAM-excluded NPIs appear as covered recipients in CMS Open Payments General Payment Data.
Denominator
8,619 active LEIE ∪ SAM NPIs (LEIE: NPI != 0000000000 AND REINDATE = 00000000; SAM: NPI matches ^[0-9]{10}$).
Data source
OIG LEIE + SAM (cms_npd BQ tables) × CMS Open Payments PY 2024 aggregate file (PBLCTN_SMRY_BY_CR_BY_NTR_OF_PYMT_PGYR2024_P01232026_01102026.csv, ~98 MB, recipient × nature-of-payment grouping). See `analysis/claims_sources/open_payments.py`.
Notes
Aggregate file (PBLCTN_SMRY_BY_CR_BY_NTR_OF_PYMT) used rather than the line-detail file (~10M rows) — the aggregate gives per-NPI × per-nature-code totals which is the right granularity for the exclusion join. Open Payments is itself public — drug and device manufacturers are required to report by the Sunshine Act / Physician Payments Sunshine Act (42 USC § 1320a-7h). AINPI's contribution is the systematic cross-join with the LEIE ∪ SAM active exclusion set, which has not been published. Per-state slices at /api/v1/states/<state>/h32-excluded-industry-payments.csv. Full national list at /api/v1/findings/excluded-receiving-industry-payments-detail.csv. Source CSV streamed once and partitioned across NDH practice states in memory.