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ehr onc final certification - Department of Health Care Services

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Response. We disagree, as doing so would run counter to our long term goals and<br />

would not help build the foundation necessary for more comprehensive capabilities to be<br />

added in the future.<br />

Comments. A few commenters noted that neither the CCD nor CCR contain an<br />

applicable section for discharge summary. One commenter recommended that because<br />

the provision <strong>of</strong> an electronic copy <strong>of</strong> discharge instructions was required by another<br />

<strong>certification</strong> criterion, that discharge instructions should be removed as an element in this<br />

electronic copy.<br />

Response. We reviewed commenters’ c<strong>onc</strong>erns and agree that there is no<br />

applicable section for a discharge summary. Therefore, we have revised this <strong>certification</strong><br />

criterion to reflect that while the other data elements can be conveyed using the patient<br />

summary record standards (CCR or CCD), we are not requiring the use <strong>of</strong> any standards<br />

for the discharge summary section. In order to support the meaningful use objective and<br />

measure, however, we note that we do expect Certified EHR Technology to be capable <strong>of</strong><br />

providing a electronic copy <strong>of</strong> a discharge summary like a patient summary record, in<br />

human readable format and on electronic media or through some other electronic means.<br />

Other electronic means could include, for example, the discharge summary represented as<br />

a CCD plus the "Hospital Course" CDA section or provided as a PDF. We have revised<br />

the <strong>certification</strong> criterion accordingly.<br />

We note that our responses to the following comments also apply to other<br />

<strong>certification</strong> criteria that reference procedures.<br />

Comments. A commenter requested clarification as to what we meant by<br />

"procedures" for hospitals, because coding for medical procedures typically occurs after<br />

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