Downcoded

Who Did Medicare Leave Off Its Four-Million-NPI List?

CMS surfaced the fourteenth edition of its missing-digital-contact-information file today: 4,034,057 individual NPIs, up 81,839 in a quarter, and the list has never once gotten shorter. Behind those names sits $81.5 billion of CY2024 Medicare payments, 82.9% of every dollar Medicare paid an individual clinician. The file also leaves off 97.2% of pathologists, and on a sample of thirty of them, twenty-five have no digital address either.


Somewhere in the comment responses to the 2020 interoperability rule, a block of commenters told CMS the plan would not work.

The plan was to publish the names and NPIs of every clinician with no digital address in NPPES. Commenters called it a policy based on "public shaming" and said it "would not serve as a meaningful deterrent to providers leaving their information blank."

CMS finalized it as proposed, at 85 FR 25584.

The fourteenth edition of that list reached the CMS data catalog today. It carries 4,034,057 NPIs, and across every vintage CMS has published, it has never once gotten shorter (chart below).

94,600 names went on this quarter and 12,761 came off. That is 7.4 on for every one off, and last quarter ran 83,533 to 10,218, so the ratio is not an artifact of one file.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

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