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<strong>CMS</strong>-1403-FC<br />

soon thereafter as is technically feasible, based upon our<br />

completion of the 2008 EHR data submission testing process<br />

and our determination that accepting data from EHRs on<br />

quality measures for the 2009 PQRI is practical and<br />

feasible. We proposed in the CY 2009 PFS proposed rule<br />

(73 FR 38564) that the date on which we will begin to<br />

accept quality data submission on services furnished in<br />

2009 would depend on having the necessary information<br />

technology infrastructure components and capacity in place<br />

and ready to accept data on a scale sufficient for national<br />

implementation of PQRI submission through this mechanism.<br />

We proposed that EHR vendors that would like to enable<br />

their customers to submit data on PQRI that is extracted<br />

from their customers’ EHRs to the <strong>CMS</strong>-designated clinical<br />

warehouse should update or otherwise assure that their EHR<br />

products capture and can submit the necessary data elements<br />

identified for measure specifications and technical<br />

specifications for EHR-based submission. We proposed that<br />

we would use Certification Commission for Healthcare<br />

Information Technology (CCHIT) criteria and the Healthcare<br />

Information Technology Standards Panel (HITSP)<br />

interoperability standards where possible and we encouraged<br />

vendors to do so also. We encouraged the use of EHRs that<br />

have <strong>been</strong> certified by the CCHIT for data submission, but<br />

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