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
Certified EHR Technology. We do not believe that limiting this certification criterion to specify that just the information available at the end of an encounter is consistent with our policy objectives. Comments. Many commenters requested a definition of “diagnostic test results.” One commenter suggested that for Stage 1, the definition of diagnostic test result be made clear and be limited to, at a minimum, lab results. Response. This term is derived from the Medicare and Medicaid EHR Incentive Programs final rule, and its meaning is described there. We encourage commenters to review the Medicare and Medicaid EHR Incentive Programs final rule. Comments. Several commenters requested that ONC define how relevant procedures are determined for the certification criterion. The commenters suggested that a subset of procedures (e.g., surgeries, catheterizations) be defined to avoid generating huge lists of “small” procedures (e.g., venipunctures). These commenters expressed that it was critical for the rule to provide a clear, clinically-relevant definition of which types of procedures are to be included. Response. We appreciate the comment and have revised this certification criterion to remove “procedures” as well as “immunizations,” to be more consistent with the final meaningful use objective and measure and for greater clarity. Comment. A commenter requested clarification on how an electronic copy will be disseminated, and provided examples such as a web-portal, email, and compact disc. Response. We do not specify the method by which an individual must receive an electronic copy of the specified health information, only that Certified EHR Technology be capable of electronically generating an electronic copy in human readable format and Page 144 of 228
in accordance with one of the adopted summary record standards. While Certified EHR Technology must be capable of creating an electronic copy of a patient’s health information as specified in this certification criterion, we encourage Complete EHR and EHR Module developers to also include the capability to generate an electronic copy in a manner that allows eligible professionals (and eligible hospitals as this capability relates to Complete EHRs and EHR Modules designed for an inpatient setting) to comply with applicable provisions of the HIPAA Privacy and Security Rules. Comment. A commenter requested that we add a requirement for alerts to prompt users to ask patients if they want a copy of their health information and include the ability to record whether the information was actually provided and the patient’s preference on the format of the information. The commenter believed that this requirement is necessary because many patients are not aware that they can make such a request. Response. While potentially useful as a reminder, we do not believe that this capability should be a condition of certification. This capability would exceed the scope of the relevant meaningful use Stage 1 objective and measure. We also note that Complete EHR and EHR Module developers are not precluded from including this capability in their EHR technology. Comment. A commenter noted that with our emphasis on the representation of clinical information in the format of a CCD or CCR, it is unclear whether the certification criterion is enough to meet patients’ expectations. Response. We recognize that this minimum information may not satisfy every patient’s interests, however, we believe that the information specified represents a core set of information that most patients will appreciate is more readily accessible to them. Page 145 of 228
- 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 and 140: specified data elements and CMS’s
- Page 141 and 142: what would qualify as a "response."
- Page 143: Comment. A commenter recommended th
- 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
- Page 191 and 192: commenter provided), our assumption
- Page 193 and 194: absolute low we estimated for a per
in accordance with one <strong>of</strong> the adopted summary record standards. While Certified EHR<br />
Technology must be capable <strong>of</strong> creating an electronic copy <strong>of</strong> a patient’s health<br />
information as specified in this <strong>certification</strong> criterion, we encourage Complete EHR and<br />
EHR Module developers to also include the capability to generate an electronic copy in a<br />
manner that allows eligible pr<strong>of</strong>essionals (and eligible hospitals as this capability relates<br />
to Complete EHRs and EHR Modules designed for an inpatient setting) to comply with<br />
applicable provisions <strong>of</strong> the HIPAA Privacy and Security Rules.<br />
Comment. A commenter requested that we add a requirement for alerts to prompt<br />
users to ask patients if they want a copy <strong>of</strong> their health information and include the ability<br />
to record whether the information was actually provided and the patient’s preference on<br />
the format <strong>of</strong> the information. The commenter believed that this requirement is necessary<br />
because many patients are not aware that they can make such a request.<br />
Response. While potentially useful as a reminder, we do not believe that this<br />
capability should be a condition <strong>of</strong> <strong>certification</strong>. This capability would exceed the scope<br />
<strong>of</strong> the relevant meaningful use Stage 1 objective and measure. We also note that<br />
Complete EHR and EHR Module developers are not precluded from including this<br />
capability in their EHR technology.<br />
Comment. A commenter noted that with our emphasis on the representation <strong>of</strong><br />
clinical information in the format <strong>of</strong> a CCD or CCR, it is unclear whether the <strong>certification</strong><br />
criterion is enough to meet patients’ expectations.<br />
Response. We recognize that this minimum information may not satisfy every<br />
patient’s interests, however, we believe that the information specified represents a core<br />
set <strong>of</strong> information that most patients will appreciate is more readily accessible to them.<br />
Page 145 <strong>of</strong> 228
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