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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equest for a consultation or a provider referral made by an eligible professional in a private practice to constitute an order that should be handled functionally through CPOE. Response. We agree with the commenter that suggested that we narrow our focus, in order to reduce the burden associated with this certification criterion. Accordingly, we have removed “provider referrals” from the certification criterion. Complete EHR and EHR Module developers may include additional orders as they see fit and as recommended by some commenters, however in order to be certified they must include at a minimum the three order types (medications, laboratory, and radiology/imaging) specified in the certification criterion. Many commenters generally supported these three specified order types and we note that while the final meaningful use Stage 1 objective focuses on medication orders, we believe that for the purposes of certification and to equip eligible professionals with a basic set of ordering capabilities, it is appropriate to continue to maintain these three order types. (This response also applies to the change we made in the CPOE certification criterion for Complete EHRs or EHR Modules designed for an inpatient setting). Finally, in further reviewing this certification criterion in light of comments received, we have also determined that it would be appropriate and clearer to replace the term “manage” with “modify” to be more consistent with the terminology used in other certification criteria. We have also made this change in the CPOE certification criterion for Complete EHRs and EHR Modules designed for an inpatient setting. Comment. A commenter stated that the lab industry does not have any standards for order entry, and even among lab providers, their operating units utilize different standards. The commenter contended that this lack of consistency in order entry would Page 126 of 228

equire EHRs to build custom interfaces to every lab. They recommended that we require that Certified EHR Technology provide the ability to link the results to the original order. Another commenter recommended that the certification criterion include the requirement for standardized bi-directional laboratory interfaces, including functionality pertinent to all the laboratory order data needed for the laboratory to conduct proper testing, patient matching and billing (including limited coverage rules and printing of Advance Beneficiary Notices (ABNs)). Response. In the certification criterion discussed above regarding incorporating laboratory test results, we have required that Certified EHR Technology be capable of electronically attributing, associating, or linking a laboratory test result to a laboratory order or patient record. Bidirectional exchange (including electronic transmission of laboratory orders) is not a requirement of meaningful use Stage 1 and is beyond the scope of this rule. Comments. Several commenters recommended we clarify that the user of CPOE includes the eligible professional and any authorized user in the office of the eligible professional (EP). They also recommended that CPOE be deemed to include the scenario in which only the actual orders are entered by the EP, with the additional billing and demographic information entered by authorized users in the EP’s office or even by third parties (e.g. laboratory personnel in the patient service center of a laboratory that collects specimens from the patient). Response. As we stated in an earlier response, the standards, implementation specifications, and certification criteria adopted in this final rule apply to Complete EHRs and EHR Modules. We have focused on whether Certified EHR Technology must Page 127 of 228

equest for a consultation or a provider referral made by an eligible pr<strong>of</strong>essional in a<br />

private practice to constitute an order that should be handled functionally through CPOE.<br />

Response. We agree with the commenter that suggested that we narrow our<br />

focus, in order to reduce the burden associated with this <strong>certification</strong> criterion.<br />

Accordingly, we have removed “provider referrals” from the <strong>certification</strong> criterion.<br />

Complete EHR and EHR Module developers may include additional orders as they see fit<br />

and as recommended by some commenters, however in order to be certified they must<br />

include at a minimum the three order types (medications, laboratory, and<br />

radiology/imaging) specified in the <strong>certification</strong> criterion. Many commenters generally<br />

supported these three specified order types and we note that while the <strong>final</strong> meaningful<br />

use Stage 1 objective focuses on medication orders, we believe that for the purposes <strong>of</strong><br />

<strong>certification</strong> and to equip eligible pr<strong>of</strong>essionals with a basic set <strong>of</strong> ordering capabilities, it<br />

is appropriate to continue to maintain these three order types. (This response also applies<br />

to the change we made in the CPOE <strong>certification</strong> criterion for Complete EHRs or EHR<br />

Modules designed for an inpatient setting). Finally, in further reviewing this <strong>certification</strong><br />

criterion in light <strong>of</strong> comments received, we have also determined that it would be<br />

appropriate and clearer to replace the term “manage” with “modify” to be more<br />

consistent with the terminology used in other <strong>certification</strong> criteria. We have also made<br />

this change in the CPOE <strong>certification</strong> criterion for Complete EHRs and EHR Modules<br />

designed for an inpatient setting.<br />

Comment. A commenter stated that the lab industry does not have any standards<br />

for order entry, and even among lab providers, their operating units utilize different<br />

standards. The commenter contended that this lack <strong>of</strong> consistency in order entry would<br />

Page 126 <strong>of</strong> 228

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