ehr onc final certification - Department of Health Care Services

commenters acknowledged and expressed in their comments, this final rule and the
Medicare and Medicaid EHR Incentive Program final rule are closely and inextricably
linked. Recognizing the unique connection between these two rules, some commenters
went so far as to issue CMS and ONC a single set of comments recommending changes
to both rules in context. Many other commenters treated both rules as almost being one
in the same, acknowledging that a change in Medicare and Medicaid EHR Incentive
Programs final rule would need to be reflected in this final rule. Other commenters
submitted comments to ONC on the Medicare and Medicaid EHR Incentive Programs
proposed rule, and to CMS on the Interim Final Rule. As we discussed previously, CMS
and ONC shared these comments between the offices and we included within our review
all comments that could be reasonably identified as comments on the Interim Final Rule.
The following three certification criteria have been adopted as part of the initial
set of certification criteria, implementation specifications, and standards in order to
realign the adopted certification criteria with the final meaningful use Stage 1
requirements and to ensure that Certified EHR Technology will provide such capabilities.
Record Advance Directives
In the Medicare and Medicaid EHR Incentive Programs proposed rule, the
Department explained that the HIT Policy Committee had recommended that eligible
hospitals “record advance directives.” Due in part to the ambiguity of the
recommendation, the Department discussed but did not include the objective “Record
Advance Directives” for the reasons explained by CMS. In its final rule, however, the
Department stated that based on comments received as well as resolution of some of the
ambiguity associated with the measure, CMS was including this objective among its
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