2015 Edition Market Readiness for Hospitals and Clinicians

1. % 2015 Base Criteria Certified is determined through an analysis of 2015 edition certified health IT modules documented in the CHPL. The percentage of certified 2015 base criteria is calculated by dividing the number of base criteria certified by a developer across all its listings by the total number of base criteria. The 2015 Edition Certification Final Rule includes a definition for the term “2015 Edition Base EHR,” which references a defined set of 2015 Edition certification criteria that all health care providers must have as part of their overall Certified EHR Technology. In some cases, to provide flexibility to its customers, a health IT developer may not certify its product to a particular Base EHR definition listed criterion. As a result, developer’s with products listed near 90% may have completed all of the certification they intended to complete. See this fact sheet for more information: https://www.healthit.gov/sites/default/files/2015edition_base_ehr_definition_ml_11-4-15.pdf.
2. % of Providers (Hospitals/Clinicians) with Developer’s Health IT Products: in the charts and tables above, a percentage is provided for each developer of the share of eligible hospitals and clinicians that reported a developer’s certified health IT product through meaningful use attestation to Medicare (i.e. developer market share). Please note that some providers report products from more than one unique developer (this is more predominant among hospitals). Therefore, the sum of these hospital and clinician percentages for all developers may exceed 100%. See methodology (1) below for more information on this calculation.
3. Approximate % ECs Required to Report to 2018 MIPS: See methodology (2) below for more information on this calculation.

Methodology:

1. % of Providers (Hospitals/Clinicians) with Developer’s Health IT Products or developer market share is approximated using public Medicare meaningful use attestation data. Counts of how many providers reported at least one health IT product certified by a developer was done separately for eligible clinicians and eligible hospitals in the same manner as similar ONC analyses and visualizations of this data for eligible professionals and hospitals. These counts only include the most recent attestation by each unique provider to avoid duplication and to consider the most recent reported data for each unique provider. Unique providers are designated by NPI (eligible professionals) and CCN (eligible hospitals) in the dataset. Market share percentages are estimated by dividing each developer’s de-duplicated count of unique provider reports by the total number of active eligible professionals (NPI is listed as active in NPPES) and hospitals (CCN is listed as active in Provider of Services (POS) file) who ever attested to meaningful through the Medicare Program.The dataset includes reports from over 95% of all active non-federal acute care hospitals, and thus reflects a nearly comprehensive view of the hospital certified health IT market. However, less than 360K eligible professionals ever attested to meaningful use through the Medicare program. These represent roughly half of all office-based physicians nationwide, and do not include non-physician professionals, such as physician assistants and advanced practice registered nurses (APRN). The MIPS eligible clinician population includes more than just physicians. It also includes APRNs and physician assistants, who were not eligible to participate in the Medicare Meaningful Use Program, and were only eligible to participate in state Medicaid Meaningful Use Programs, for which we lack certified health IT product data. Because we lack health IT market data on these non-physician clinician populations, market share rates are biased toward those software chosen by physicians and physician-led practices. Therefore, the market share percentages for eligible clinicians should be treated as approximations. Though they do closely mirror those approximated by other sources.
2. Approximate % ECs Required to Report to 2018 MIPS are approximated using publicly available Medicare Part B physician payment data. In 2018, clinicians eligible to participate in MIPS, based on their specialty, are exempt from reporting, as an individual, if they meet one of two thresholds: (i) if the clinician did not have allowable Medicare charges greater than $90K at any practice to which she is a member, and/or (ii) if the clinician did not treat more than 200 unique Medicare beneficiaries at any practice to which she is a member (https://qpp.cms.gov/). ONC’s approximations use the payment data from the 2015 Medicare Physician Utilization and Payment Aggregate Dataset to estimate those eligible clinicians, who have previously attested to meaningful use through Medicare, that are exempt from reporting for 2018 MIPS. For this approximation, we used (i) the payment data in data field, “total_medicare_allowed_amt”, to determine if a clinician made less than $90K in allowable charges to Medicare, and (ii) “total_unique_benes” to determine if a clinician treated less than 200 unique Medicare beneficiaries. If an individual clinician met either of these criteria, she was considered exempt for 2018 MIPS. This method, however, does limit the accuracy of the approximation:
   (a) CMS’ MIPS low-volume exemption policy makes determinations based off allowable charges and unique beneficiaries by a unique NPI at a unique TIN (tax identification number associated with a unique practice location). Our approximation uses for a unique NPI the sum of all allowed charges and sum of all unique beneficiaries, as provided in the referenced dataset. Because a clinician may have more than $90K total allowed charges (or more than 200 unique beneficiaries) across all practices, but still not have more than $90K allowed charges (or more than 200 unique beneficiaries) at any individual practice, this approximation may underestimate the number of exempt clinicians.
   (b) These approximations use 2015 Medicare claims data. 2018 MIPS exemption determinations use claims data from September 1, 2016 through August 31, 2017. Therefore, these approximations may misestimate total exemptions if eligible clinicians’ allowable charges differ between 2015 and 2017.
   (c) MIPS allows individual clinicians the option to report as an individual or as part of a group or virtual group. These percentages reflect only individual eligible clinicians and do not reflect group or virtual group eligibility. For clinicians in groups with more than one clinician, their individual charges and unique beneficiaries may exempt them from reporting as an individual, but allow them to report as part of a group or virtual group if their group exceeds the exemption thresholds.Given these limitations, the approximate percentage of clinicians (by developer) not exempt (required to report) for 2018 MIPS may differ from percentages based off actual eligibility determinations. Though the estimated percentages may vary from the actual percentages, these approximations do allow for comparisons of percentages across developers, as we assume any differences carry across all developers.