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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10.08.2013 Views

an alternative to NCPDP SCRIPT 8.1 for the electronic transmission of prescription and certain other prescription-related information for Medicare Part D covered drugs prescribed for Part D eligible individuals (75 FR 38026). Further, we stated that “if SCRIPT 10.6 is permitted, prior to any modification of the provisions of this interim final rule in response to public comment, we would expect to change our requirement to simply permit either SCRIPT 8.1 or SCRIPT 10.6.” Accordingly, we have modified this certification criterion to specify that Complete EHR and EHR Module developers may seek to have their Complete EHR or EHR Module tested and certified to either solely NCPDP SCRIPT 8.1 or 10.6. Additionally, we have also replaced the standard adopted in the Interim Final Rule and have adopted both NCPDP SCRIPT 8.1 and NCPDP SCRIPT 10.6. As discussed in the beginning of the preamble, we have revised our approach to specifying the certification criteria to more clearly focus on the capabilities with which they must be associated. Therefore, we have modified this certification criterion to specify that a Complete EHR or EHR Module would be compliant with this certification criterion if it has the capability of generating and transmitting prescription and prescription-related information according to NCPDP SCRIPT 8.1 while also using the adopted vocabulary standard, or if it is capable of generating and transmitting prescriptions and prescription-related information according to NCPDP SCRIPT 10.6 while also using the adopted vocabulary standard. Comments. Several commenters supported the adoption of RxNorm and the use of RxNorm code sets as a vocabulary standard. One commenter recommended that RxNorm be adopted in Stage 1 while one commenter stated that Stage 2 is likely the earliest timeframe practicable for implementation. Others suggested that more testing Page 130 of 228

was needed before RxNorm could be adopted in full. Some commenters stated that RxNorm is not complete and requested guidance on how gaps in RxNorm will be addressed. A couple commenters stated a concern that current drug databases do not map to RxNorm and that in order to develop interfaces for electronic prescribing services, pharmacies and developers will need to expend significant effort. Other commenters stated that more clarification was needed with respect to the description of the adopted standard and one of those commenters recommended that the description be changed to “a drug data source provider that demonstrates group domain comprehensiveness.” Response. We have consolidated and addressed our adopted vocabulary standard for medications under this certification criterion. However, our response and subsequent clarifications are applicable to all certification criteria that reference this vocabulary standard. As we explained in the Interim Final Rule, we determined that the HIT industry would benefit from a certain degree of flexibility with respect to the coding of medications. To provide this flexibility while also establishing a glide path to full adoption of RxNorm, we adopted a standard that permits the use of one of many different vocabulary standards. We specified that a Complete EHR or EHR Module would be compliant with the adopted vocabulary standard if it utilized “[a]ny code set by an RxNorm drug data source provider that is identified by the United States National Library of Medicine as being a complete data set integrated within RxNorm.” We specified the standard this way in order to establish what we believe is an important bridge to full RxNorm adoption and will help facilitate this transition over time. Our adoption of this standard stems from our belief that Complete EHRs and EHR Modules Page 131 of 228

was needed before RxNorm could be adopted in full. Some commenters stated that<br />

RxNorm is not complete and requested guidance on how gaps in RxNorm will be<br />

addressed. A couple commenters stated a c<strong>onc</strong>ern that current drug databases do not map<br />

to RxNorm and that in order to develop interfaces for electronic prescribing services,<br />

pharmacies and developers will need to expend significant effort. Other commenters<br />

stated that more clarification was needed with respect to the description <strong>of</strong> the adopted<br />

standard and one <strong>of</strong> those commenters recommended that the description be changed to<br />

“a drug data source provider that demonstrates group domain comprehensiveness.”<br />

Response. We have consolidated and addressed our adopted vocabulary standard<br />

for medications under this <strong>certification</strong> criterion. However, our response and subsequent<br />

clarifications are applicable to all <strong>certification</strong> criteria that reference this vocabulary<br />

standard.<br />

As we explained in the Interim Final Rule, we determined that the HIT industry<br />

would benefit from a certain degree <strong>of</strong> flexibility with respect to the coding <strong>of</strong><br />

medications. To provide this flexibility while also establishing a glide path to full<br />

adoption <strong>of</strong> RxNorm, we adopted a standard that permits the use <strong>of</strong> one <strong>of</strong> many different<br />

vocabulary standards. We specified that a Complete EHR or EHR Module would be<br />

compliant with the adopted vocabulary standard if it utilized “[a]ny code set by an<br />

RxNorm drug data source provider that is identified by the United States National<br />

Library <strong>of</strong> Medicine as being a complete data set integrated within RxNorm.” We<br />

specified the standard this way in order to establish what we believe is an important<br />

bridge to full RxNorm adoption and will help facilitate this transition over time. Our<br />

adoption <strong>of</strong> this standard stems from our belief that Complete EHRs and EHR Modules<br />

Page 131 <strong>of</strong> 228

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