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
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
- Page 75 and 76: or outreach Generate patient lists.
- Page 77 and 78: months). We believe that these revi
- Page 79 and 80: that the PQRI 2009 Registry XML spe
- Page 81 and 82: To better align this certification
- Page 83 and 84: the capability specified by the cer
- Page 85 and 86: vendors were unwilling or unable to
- Page 87 and 88: the concerns expressed by some comm
- Page 89 and 90: Page 89 of 228 electronically compa
- Page 91 and 92: (1) The standard (and applicable im
- Page 93 and 94: for the purposes of demonstrating c
- Page 95 and 96: Guide for Immunization Messaging Re
- Page 97 and 98: Response. We clarify for commenters
- Page 99 and 100: serve as a limiting factor, however
- Page 101 and 102: Page 101 of 228 Unchanged Comment.
- Page 103 and 104: Comment. One commenter suggested th
- Page 105 and 106: Response. We appreciate the thought
- Page 107 and 108: Complete EHRs or EHR Modules design
- Page 109 and 110: Response. We disagree. As stated ab
- Page 111 and 112: Response. As discussed above, we ha
- Page 113 and 114: SHA-1 and other secure hash algorit
- Page 115 and 116: misinterpreted our example and stat
- Page 117 and 118: Other commenters also expressed con
- Page 119 and 120: eferenced in FIPS 140-2 Annex A, wh
- Page 121 and 122: of the most secure encryption algor
- Page 123 and 124: the disclosure was made (recipient)
- Page 125: Use CPOE for medication orders dire
- Page 129 and 130: esult, we do not believe that this
- Page 131 and 132: was needed before RxNorm could be a
- Page 133 and 134: • MDDB - Medi-Span Master Drug Da
- Page 135 and 136: Response. We do not believe that it
- Page 137 and 138: Send reminders to patients per pati
- Page 139 and 140: specified data elements and CMS’s
- Page 141 and 142: what would qualify as a "response."
- Page 143 and 144: Comment. A commenter recommended th
- Page 145 and 146: in accordance with one of the adopt
- Page 147 and 148: Comments. Many commenters suggested
- Page 149 and 150: flexibility in this certification c
- Page 151 and 152: productive, confusing, time-consumi
- Page 153 and 154: include in this initial set. Accord
- Page 155 and 156: to the HITSP C32 implementation spe
- Page 157 and 158: Response. Again, we do not believe
- Page 159 and 160: e achieved without these and recomm
- Page 161 and 162: electronically record, store, retri
- Page 163 and 164: EHRs and EHR Modules designed for a
- Page 165 and 166: §170.205(a)(2)(iii); and (v) The s
- Page 167 and 168: Response. We disagree, as doing so
- Page 169 and 170: Dental Terminology as a condition o
- Page 171 and 172: However, we do not preclude Complet
- Page 173 and 174: ability of CCD and CCR to support t
- Page 175 and 176: ability to receive these reports. M
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 />
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