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ehr onc final certification - Department of Health Care Services

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Meaningful Use<br />

Stage 1<br />

Objective<br />

Protect electronic<br />

health information<br />

created or<br />

maintained by the<br />

certified EHR<br />

technology through<br />

the implementation<br />

<strong>of</strong> appropriate<br />

technical<br />

capabilities<br />

Meaningful Use<br />

Stage 1 Measure<br />

Conduct or review<br />

a security risk<br />

analysis per 45<br />

CFR 164.308 (a)(1)<br />

and implement<br />

security updates as<br />

necessary and<br />

correct identified<br />

security<br />

deficiencies as part<br />

<strong>of</strong> its risk<br />

management<br />

process<br />

Page 104 <strong>of</strong> 228<br />

Certification Criterion<br />

Interim Final Rule Text:<br />

(1) Record actions. Record actions related to electronic health<br />

information in accordance with the standard specified in<br />

§170.210(b).<br />

(2) Alerts. Provide alerts based on user-defined events.<br />

(3) Display and print. Electronically display and print all or a<br />

specified set <strong>of</strong> recorded information upon request or at a set<br />

period <strong>of</strong> time.<br />

Final Rule Text:<br />

§170.302(r)<br />

(1) Record actions. Record actions related to electronic health<br />

information in accordance with the standard specified in<br />

§170.210(b).<br />

(2) Generate audit log. Enable a user to generate an audit log<br />

for a specific time period and to sort entries in the audit log<br />

according to any <strong>of</strong> the elements specified in the standard at<br />

170.210(b).<br />

Comments. Several commenters recommended that we add to the standard<br />

specified at §170.210(b) “access,” “reading,” or “viewing” as triggers for when actions<br />

needed to be recorded as part <strong>of</strong> an audit log. One commenter recommended expanding<br />

the audit content to include maintaining the before-access content <strong>of</strong> the information<br />

accessed as well as the after-access content. Some commenters requested clarification <strong>of</strong><br />

the intended meaning <strong>of</strong> the reference to recording the action <strong>of</strong> “printing.” Commenters<br />

recommended expanding or replacing “print” in the standard with other types <strong>of</strong> output<br />

methods such as extraction, copy, exchange, report, and export. Some commenter stated<br />

that the print function in many operating systems and s<strong>of</strong>tware products is a multiple step<br />

process that is difficult for any system to audit. Other commenters expressed c<strong>onc</strong>erns<br />

that the requirement to audit all printing would be difficult because there were numerous<br />

ways to circumvent the specific action <strong>of</strong> printing, such as using the print screen function<br />

and printing out the image <strong>of</strong> the screen shot. One commenter stated that auditing <strong>of</strong> the<br />

print function would be possible, but complete auditing <strong>of</strong> all possible ways <strong>of</strong> printing<br />

would be impracticable.

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