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ehr onc final certification - Department of Health Care Services

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Comment. A commenter suggested that ONC strike the following from the<br />

<strong>certification</strong> criteria “and upon receipt <strong>of</strong> a patient summary record formatted in an<br />

alternate standard specified in §170.205(a)(1), display it in human readable format.”<br />

Another commenter stated that data transport is not addressed in the standards, and the<br />

criterion instead refers to “transmit.” The commenter suggested changing the first part <strong>of</strong><br />

the criterion to “display” instead <strong>of</strong> “receive,” and the second part <strong>of</strong> the criterion to<br />

“export” instead <strong>of</strong> “transmit.”<br />

Response. We disagree and have not made these changes. We believe that this<br />

<strong>certification</strong> criterion expresses the capabilities we expect Certified EHR Technology will<br />

include. Furthermore, the action <strong>of</strong> “exporting” a patient summary record does not<br />

indicate or require that Certified EHR Technology is actually capable <strong>of</strong> transmitting a<br />

patient summary record to Certified EHR Technology implemented by a different eligible<br />

pr<strong>of</strong>essional or eligible hospital.<br />

Comment. A commenter requested clarification on how historical data from<br />

paper records should be treated for the purpose <strong>of</strong> <strong>certification</strong>. If historical data is on<br />

paper, the standards for display are inapplicable.<br />

Response. Data from paper records would not be a relevant factor for the<br />

purposes <strong>of</strong> testing and <strong>certification</strong>. We are c<strong>onc</strong>erned with whether Complete EHRs<br />

and EHR Modules have implemented specific capabilities in compliance with the<br />

<strong>certification</strong> criteria adopted by the Secretary.<br />

Comments. A couple <strong>of</strong> commenters requested definition <strong>of</strong> “diagnostic test<br />

result” and “procedures” in the context <strong>of</strong> this criterion.<br />

Page 156 <strong>of</strong> 228

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