ehr onc final certification - Department of Health Care Services

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laboratory test results. (2) Notifications. Automatically and electronically generate and indicate in real-time, notifications and care suggestions based upon clinical decision support rules. Comments. Several commenters were explicitly supportive of this certification criterion, while others offered specific suggestions and requests for clarification. Several commenters requested that we specify the decisions support rules that should be included. One commenter asked if we could clarify whether a Complete EHR or EHR Module developer would have to include specific rules that individual eligible professionals would want or whether those rules could be added later. Another commenter asked for clarification regarding several terms including “diagnostic test results,” whether a “condition” was equivalent to “problem,” as well as whether the rules would be associated with quality measures. Response. In consideration of commenters’ request for clarification and to more closely align this certification criterion with the meaningful use measure, we have revised this certification criterion. We have removed the terms that caused some confusion with commenters and believe that these revisions will provide more specificity and will make compliance with the certification criterion easier. Moreover, we clarify that with respect to notifications, that “real-time” means at the point of clinical decision making (i.e., notifications must be provided when an eligible professional is using Certified EHR Technology and not run overnight and provided in the morning, for instance). Comments. A number of commenters asked questions and requested clarifications regarding “alerts.” One commenter requested whether it is the number of alerts that is important or the type of alerts that is important and how we expect an eligible professional to respond to an alert. The commenter also asked if we could clarify Page 140 of 228
what would qualify as a "response." One commenter stated that whether we intended for the examples (pop-up or sound) to be inclusive of the types of alerts we expected Certified EHR Technology would include and whether this was deemed more valuable than a more passive notification. The commenter suggested that the word “alert” be replaced with “notification” while another suggested the word “advisory.” Some commenters requested clarification regarding “alerts responded to by a user” and whether there was an expectation that alerts communicate structured reasons. These commenters also asked whether users would enter a reason for any overrides or, in the case of notifications, the user would simply acknowledge the alert by clicking “OK.” The commenters also questioned whether ignored alerts should be tracked? Many of these commenters recommended removing §170.304(e)(3). Alternatively, one commenter recommended that we not only consider the number of alerts “responded to” but also the action prompted and whether or not that action was taken. Response. We thank commenters for the thorough feedback on this certification criterion. We have already addressed in our responses above the concerns raised by commenters and will not repeat them here. With respect to the third part of this certification criterion, we have considered public comment and have decided to remove the requirement from the certification criterion. We also removed this requirement to be more consistent with CMS’s expectations for meaningful use, which do not include requiring the tracking of alerts at this time. Comments. A few commenters asked for clarification on what we meant by "evidence grade" and what standard for evidence grading will be applied in order to determine compliance with this objective. Other commenters noted that “evidence Page 141 of 228
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DEPARTMENT OF HEALTH AND HUMAN SERV
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HHS Department of Health and Human
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5. Definition of Qualified EHR 6. D
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technology. Section 3004(b)(1) of t
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esolve identified technical challen
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Some commenters appear to have misi
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efficiencies and desired quality im
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codes must be used “inside” an
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not necessarily have applied to our
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3. Definition of Implementation Spe
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program established by the National
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criteria adopted by the Secretary a
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Comment. In the context of the defi
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y the certification criteria for a
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commenters asked whether we meant t
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adopted by the Secretary. The secon
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Response. We would like to make cle
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Response. In the Interim Final Rule
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could be a health care professional
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standard for certain purposes. In s
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e voluntary and would not be requir
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already existing regulatory require
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setting). We also include, where ap
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clarification on why the number of
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more clearly specify this capabilit
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Response. While we do not require t
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that check, the functionality show
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Response. The comments are correct
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enable the user to electronically r
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longitudinal care, or whether the E
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EHR and EHR Module developers to pr
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suggestions for different age range
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Record smoking status for patients
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23) during the EHR reporting period
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laboratory test results are receive
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commenters reasoned that because a
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laboratory test results to be elect
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or outreach Generate patient lists.
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months). We believe that these revi
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that the PQRI 2009 Registry XML spe
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To better align this certification
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the capability specified by the cer
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vendors were unwilling or unable to
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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 and 126: Use CPOE for medication orders dire
Page 127 and 128: equire EHRs to build custom interfa
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: specified data elements and CMS’s
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
Page 177 and 178: commenters acknowledged and express
Page 179 and 180: a meaningful use objective they wou
Page 181 and 182: CMS and ONC had worked together to
Page 183 and 184: The eligible professional or eligib
Page 185 and 186: EHR technology with the needs of us
Page 187 and 188: The RFA requires agencies to analyz
Page 189 and 190: values seemed low and that the gap
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commenter provided), our assumption
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absolute low we estimated for a per
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number of previously CCHIT-certifie
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for Certification Low High Page 197
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Finally, the third type of cost we
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2012 15% $10.10 $30.80 $20.45 3-Yea
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The RFA requires agencies to analyz
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The Office of Management and Budget
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The standards and implementation sp
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The Secretary adopts the following
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any edition other than that specifi
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(e) Regenstrief Institute, Inc., LO
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4. Revise subpart C to read as foll
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smoker; current some day smoker; fo
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(2) Generate audit log. Enable a us
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(3) Medication allergy list; (4) De
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§170.205(a)(1) or §170.205(a)(2).
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(d) Electronic copy of health infor
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specifications) specified in §170.
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