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ehr onc final certification - Department of Health Care Services

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Several commenters requested clarification <strong>of</strong> the term “upon request.” One commenter<br />

wanted to know which persons would be authorized to request the patient reminder list<br />

and how <strong>of</strong>ten. Another commenter suggested that the phrase “upon request” be<br />

removed, as it believed that outpatient physicians could make significant advances in the<br />

health <strong>of</strong> their patients by generating and delivering reminders at every encounter.<br />

Response. In response to comments, we have revised this <strong>certification</strong> criterion to<br />

more clearly articulate the capability we expect Certified EHR Technology to include.<br />

CMS discusses and clarifies the intended meaning <strong>of</strong> “patient preferences” in the<br />

Medicare and Medicaid EHR Incentive Programs <strong>final</strong> rule and because this term is<br />

derived from the meaningful use objective, we encourage commenters to review CMS’s<br />

responses to their requests for clarification. Consistent with the revisions we made to the<br />

“generate patient lists” <strong>certification</strong> criterion, we believe that Certified EHR Technology<br />

should be able to leverage the information, specifically the structured data it had available<br />

to it, to assist eligible pr<strong>of</strong>essionals and eligible hospitals generate a patient reminder list.<br />

We have removed “upon request” from the <strong>certification</strong> criterion, because, after further<br />

review, we believe that the action <strong>of</strong> requesting a list is implied by the <strong>certification</strong><br />

criterion and the meaningful use measure, and therefore, unnecessary to further specify.<br />

Comments. Two commenters stated that specialists will use patient reminders<br />

differently than primary care providers. These commenters worried that some patients'<br />

preferences may exceed a system's current capabilities and one commenter requested that<br />

the phrase “with respect to system capability” be added after “patient preferences.”<br />

Response. We understand these commenters’ points <strong>of</strong> view, however, we do not<br />

believe that this addition is necessary given the references in the <strong>certification</strong> criterion to<br />

Page 138 <strong>of</strong> 228

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