Sunshine Act reporting in 2026: meal limits and employee travel compliance

Under the Physician Payments Sunshine Act, manufacturers of covered drugs, medical devices, biologicals, and medical supplies must publicly report certain “transfers of value”—including meals, travel, and transportation—provided to healthcare professionals through the CMS Open Payments program.

For commercial, field, and operations teams, activities like hosting a lunch-and-learn with physicians or arranging conference travel can carry reporting implications.

In this article, we’ll explore how the Sunshine Act and Open Payments requirements intersect with meals, rides, and travel and how teams can design programs that are easier to manage, review, and scale.

What is the Sunshine Act?

The Physician Payments Sunshine Act, enacted as part of the Affordable Care Act, requires manufacturers of drugs, medical devices, and biologicals that participate in US federal healthcare programs to report certain payments and other “transfers of value” made to healthcare providers and teaching hospitals. Reports are due annually to the Centers for Medicare & Medicaid Services (CMS) and published through the Open Payments program to promote transparency and reduce potential conflicts of interest.

What counts as a transfer of value?

Under Open Payments reporting guidance, transfers of value can include more than direct payments. Categories commonly reported include these:

Food and beverage
Travel and lodging
Transportation
Consulting fees, honoraria, and education
Research-related payments
Ownership or investment interests

For example, when a pharmaceutical sales team hosts a lunch-and-learn with physicians or sponsors travel to a conference, the associated food, transportation, and lodging expenses may qualify as reportable transfers of value under Open Payments.

For manufacturers and commercial teams, this means that meals, transportation, and travel involving healthcare professionals may qualify as reportable transfers of value depending on context, recipients, and thresholds.

Reporting thresholds and covered recipients

As of the most recent CMS guidance, individual transfers of value over a small-dollar threshold are reportable, as are multiple smaller transfers that exceed an annual aggregate amount. CMS updates these thresholds annually as part of the Open Payments reporting cycle.

Covered recipients include physicians (MD and DO), dentists, podiatrists, optometrists, chiropractors, and—following regulatory expansion—advanced practice providers such as nurse practitioners and physician assistants.

Why commercial and operations teams feel the pressure

Commercial, field, and operations teams often coordinate activities involving healthcare professionals, including:

Lunch-and-learns with physicians
Travel and lodging for conferences or training
Transportation tied to field engagements

In regulated environments, these activities are reviewed through multiple lenses. Finance teams want clean billing and clear categorization. Legal and compliance teams want consistent documentation aligned with Open Payments reporting.

When programs rely on reimbursements, manual receipt collection, or multiple vendors, even relatively small expenses can create disproportionate administrative work and slow internal approvals.

What strong programs do differently

Across regulated industries, well-run employee programs tend to share 3 characteristics:

Clear policies

Defined spending limits, eligible categories (meals, rides, travel), timing, and locations reduce ambiguity before a program launches.

Controls at the point of use

Applying limits before spending occurs reduces exceptions, manual review, and rework.

Centralized reporting

Consolidated visibility across programs makes it easier to support internal review and respond to audit or compliance questions.

These practices align with CMS transparency expectations while helping workplace teams operate more efficiently.

How Uber for Business supports workplace teams

Uber for Business helps organizations manage meals, rides, and travel with policy controls and centralized visibility—supporting clearer internal documentation and review processes in regulated environments.

With Uber for Business, administrators can:

Set spending limits and usage rules for meals and rides
Centralize billing and program visibility in a single dashboard
Maintain consistent records that support internal finance and compliance review

Employees use the Uber and Uber Eats apps they already know, while admins retain control behind the scenes.

Planning for 2026

As regulatory expectations and internal scrutiny continue into 2026, workplace teams benefit from designing programs that prioritize clarity and consistency from day one. Clear policies, automated controls, and centralized reporting reduce friction, shorten approval cycles, and help programs scale with confidence.

If you’re looking to simplify how your organization manages employee meals, rides, and travel in regulated environments, Uber for Business can help. Connect with us to find out more.

Talk to our team