ehr onc final certification - Department of Health Care Services

list, procedures, etc. are commonly referred to as “sections” of the CDA or CCD
document, not "fields." They stated that sections may contain narrative text using the
CDA XML format for text, and need not contain level 3 entries; however, they believed
that in order to use the specified clinical vocabularies found in the Interim Final Rule in
an interoperable fashion, the codes from these selected vocabularies must appear in level
3 entries. Some commenters also noted this and recommended that we adopt CCD and
specify that the standard must be implemented in accordance with the HITSP C32
implementation specification, using the vocabulary standards we had adopted in the
Interim Final Rule. One commenter noted that units of measure are components of
structured entries (CDA level 3) in these sections. The commenter supported specified
clinical vocabularies and level 3 CCD because the commenter felt that level 3 would be
necessary to properly communicate the information.
Response. We have considered public comments and, in response, have made
two changes. Both are related to our adoption of the CCD standard. In the Interim Final
Rule we explicitly included a reference to “level 2” to indicate that we expected a
Complete EHR or EHR Module would be capable of generating a level 2 CCD. After
further consideration, we agree that removing “level 2” from the adopted standard will
help clarify the requirements regarding the implementation of CCD. As some
commenters pointed out, the coded data elements we expect to populate the fields of the
CCD would necessitate “level 3” entries. Thus, we have removed the reference to “level
2.” We also agree, that the HITSP C32 (version 2.5) implementation specification for
CCD would be appropriate to adopt. We understand that a majority of Complete EHR
and EHR Module developers who have implemented the CCD standard do so according
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