ehr onc final certification - Department of Health Care Services

to respond to public comments received. Certification criteria and associated standards
and implementation specifications will be used to test and certify Complete EHRs and
EHR Modules in order to make it possible for eligible professionals and eligible hospitals
to adopt and implement Certified EHR Technology. The use of Certified EHR
Technology is one of the requirements an eligible professional or eligible hospital needs
to meet in order to qualify for an incentive payment under the Medicare and Medicaid
EHR Incentive Programs.
C. Executive Order 12866 – Regulatory Planning and Review Analysis
1. Comment and Response
Comments. A few commenters offered opinions related to the cost estimates
included in the Interim Final Rule. One commenter disagreed with our approach. This
commenter contended that our analysis followed a simplistic, linear model that did not
account for the other potential costs that Complete EHR and EHR Module developers
and health care providers would bear. The commenter suggested that we address other
costs in our calculations including: whether a Complete EHR or EHR Module developer
has adequate resources available to modify its HIT in order to prepare for certification;
the loss of a Complete EHR or EHR Module developer’s net worth and dislocation of
jobs if it fails and goes out of business; and the resulting impacts that would occur if a
Complete EHR and EHR Module developer went out of business and left behind
customers (some or many of which could then be ineligible for Medicare and Medicaid
EHR Incentive Programs) with unsupported HIT. Another commenter questioned the
cost estimates in the Interim Final Rule, but acknowledged that it was not prepared to
offer alternative cost estimates. The commenter did state that it believed our dollar
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