ehr onc final certification - Department of Health Care Services
ehr onc final certification - Department of Health Care Services
ehr onc final certification - Department of Health Care Services
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adopted in the Interim Final Rule as part <strong>of</strong> the integrity <strong>certification</strong> criterion that<br />
specified that Certified EHR Technology must be capable <strong>of</strong> detecting alterations to audit<br />
logs. We encourage the HIT Standards Committee to consider additional capabilities that<br />
could be specified related to audit logs.<br />
Comment. One commenter recommended that the IHE Audit Trail and Node<br />
Authentication (ATNA) Integration Pr<strong>of</strong>ile be used, but that its use be constrained to the<br />
electronic transactions among organizations, rather than electronic transmissions within<br />
an organization.<br />
Response. We decided to defer our adoption <strong>of</strong> the ATNA standard because it<br />
can be configured in multiple ways and we did not believe that it would be appropriate at<br />
this time to require a specific implementation as a condition <strong>of</strong> <strong>certification</strong>. Our deferral<br />
does not preclude Complete EHR and EHR Module developers from using the standard,<br />
however.<br />
Comment. One commenter requested clarification between “read” audits and<br />
“write” audits, and how each is to be used. The commenter suggested that not requiring<br />
the capability <strong>of</strong> “read” audits will significantly reduce the ability <strong>of</strong> auditors to identify<br />
and investigate inappropriate use <strong>of</strong> health information when records are accessed but not<br />
manipulated. The commenter noted that auditing all read operations for all data elements<br />
within an EHR is infeasible. The commenter further suggested that “read” operations<br />
should be audited only when certain demographic health information needed to identify a<br />
patient (e.g., name, record number, date <strong>of</strong> birth, address) is presented to or can be known<br />
by the user.<br />
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