ehr onc final certification - Department of Health Care Services

productive, confusing, time-consuming, and reduce interoperability. Of the commenters
that supported the adoption of CCR, most expressed their appreciation for the flexibility
we had provided. These commenters contended that CCR was easier to implement and
would make it easier for smaller Complete EHR and EHR Module developers to enter the
market and get certified. One commenter suggested that if we intended to keep both
CCD and CCR as adopted standards that we specify the transactions for which each
standard should apply. This commenter recommended that CCD be used for exchanging
summary records between health care providers and that CCR be used for exchanging
summary records to PHRs. Of the commenters that opposed our selection of CCR, many
of them recommended that we adopt the CCD standard as the sole standard for summary
records. These commenters principally referenced that the CCD was a harmonization of
CDA and CCR. Some commenters stated that we did not provide sufficient rationale for
adopting CCR and we had reopened a debate over the two standards that was purportedly
previously settled. Some commenters were concerned that CCR could not support
certain information, particularly, in the hospital setting. These commenters contended
that CCR could not support discharge information and that CCR cannot provide input
into clinical decision support due to the lack of a common definition of how data is
structured. Other commenters referenced that CCR is not extensible and questioned its
ability to be used for quality reporting. Several commenters recommended that, short of
adopting solely CCD, we provide clearer guidance to the industry regarding what
standard we expect to adopt for future stages of meaningful use because CCD and CCR
are not based on a common information model.
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