Every hospital in the CMS Promoting Interoperability program has to name the certified health IT products it used. 1,487 hospitals on Epic named nothing but Epic. Here is all 4,046 of them, at once.
Federal investigators have two questions about Epic, according to STAT. Whether the non-competes keep employees from leaving. And whether Epic’s leverage over hospitals keeps competitors from reaching patient data.
The second question has a public file attached to it. Nobody built it to answer this — it exists so CMS can verify that a hospital used certified technology — but it happens to record, for 4,046 hospitals, exactly which software vendors were named on the same form.
An Epic hospital reports an average of 0.23 non-base certified developers. Everyone else reports 1.58. Whatever is producing that gap, it is not subtle and it is not noise — there are 4,046 hospitals in the file and 89 developers.
The first thing anyone says is that Epic hospitals are big academic systems that build in-house. You can check that.
Joining the file to CMS’s Hospital General Information data splits every hospital into acute care or critical access. If size were the story, the gap should shrink inside each stratum. It does not move.
The fourteen most-reported non-base developers in the file, as a share of the hospitals that could have named them.
SUBSTITUTION, NOT EXCLUSION
The certified-product list is a compliance surface: electronic case reporting, syndromic surveillance, eCQM calculation, e-prescribing. Epic ships modules for all of it. A MEDITECH community hospital has to go buy Medisolv or Inpriva to close the same gap — which is exactly why not one MEDITECH hospital in the file sits in the zero column, and why Medisolv appears at 21.7% of non-Epic hospitals and 3.1% of Epic ones.
So “zero third-party certified products” is what product completeness looks like from the outside. In this file it is indistinguishable from what exclusion looks like. That is the honest ceiling on the chart above.
And certification is not integration. Almost none of the clinical AI running in an Epic shop today needed ONC certification, so almost none of it is on this list — no ambient documentation vendors, no imaging triage, no sepsis models. This file counts a regulatory artifact, not a market.
Self-reported, unaudited, one program year. Hospitals fill in their own certified-product list for program year 2023. Nothing checks it. A hospital naming one product instead of four could be a procurement fact or reporting fatigue, and the file cannot tell you which.
The denominator is a program, not a country. Only hospitals participating in Promoting Interoperability appear. Facilities outside Medicare and Medicaid, and hospitals using certified technology without attesting, are simply absent. Roughly 550 of the 4,593 facilities in the raw file named no developer at all and are excluded from every figure here.
“Base EHR” is our line, not CMS’s. We treat Epic, Cerner, MEDITECH, TruBridge, Altera, MEDHOST and HCA’s internal IT group as base EHRs and everything else as third-party. A hospital naming Epic is classified Epic regardless of what else it names. Move that line and the absolute levels move; the direction does not.
Nothing here establishes wrongdoing. Epic’s position is that it is a leader in interoperability and does not engage in anticompetitive behavior. No charges have been filed against anyone.
The countable thing is 0.23 versus 1.58. The thing an FTC inquiry can compel and a public file cannot produce is the other one: what a third party has to agree to in order to read a chart. API terms. App-review timelines. The contract language between Epic and a hospital about running a competing tool. The CureIS complaint alleges an “Epic-first” policy requiring customers to drop third-party tools even where Epic has no equivalent product. Epic has moved to dismiss.
Every clinical AI company in the country built on the assumption that this question would not get asked out loud. It just did. The dot field is not the answer — it is the shape of the thing being asked about.