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
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e achieved without these and recommends that implementation guidance be issued that<br />
includes specific references to content or vocabulary standards.<br />
Response. We have not adopted standards for radiology reports or images;<br />
however, both the CCR and CCD can be used to convey narrative text and objects such<br />
as scanned documents.<br />
Comments. A couple <strong>of</strong> commenters requested clarification as to the testing we<br />
expected to occur related to a Complete EHR or EHR Module’s compliance with this<br />
<strong>certification</strong> criterion. These commenters questioned whether the generation <strong>of</strong> a CCD<br />
and XDS (HITSP/TP13)/FTP/email <strong>of</strong> a document would meet the <strong>certification</strong> criterion<br />
requirements.<br />
Response. We clarify that because we have removed the adopted transport<br />
standards, we do not require as a condition <strong>of</strong> <strong>certification</strong> that a specific transport<br />
standard be used to transmit a generated CCD.<br />
Comments. One commenter expressly agreed with the expectations <strong>of</strong> the<br />
<strong>certification</strong> criterion. Another commenter stated that this functionality is crucial to<br />
support the patient/family-centered medical home. One commenter recommended that<br />
the Certified EHR Technology be designed so that the amount <strong>of</strong> data transmitted could<br />
be adjusted by physicians so they do not violate the HIPAA Privacy Rule’s “minimum<br />
necessary” requirements.<br />
Response. We appreciate commenters’ support for this <strong>certification</strong> criterion and<br />
agree that patient summary records serve a valuable purpose. Presently, we do not<br />
believe that it is appropriate to require as a condition <strong>of</strong> <strong>certification</strong> a capability<br />
associated with the HIPAA Privacy Rule’s minimum necessary requirements because<br />
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