ehr onc final certification - Department of Health Care Services

equirements. The commenter requested that HHS provide assistance to EHR vendors
with revenues of less than $1 million in order to help offset the costs of the certification
process.
Response. We appreciate commenters’ recommendations and suggestions related
to our cost analysis. While we understand why some commenters recommended
additional factors for us to consider as part of our analysis, we do not believe many of
those factors are relevant for two primary reasons: 1) we believe that it is improbable that
this rule will result in the outcomes speculated and their associated costs; and 2) the
factors contributing to or causing the increased costs are outside the scope of this rule
(e.g., hypothetical business failure and job loss, workflow redesign) and could not be
reasonably or accurately estimated. In this regard, we reiterate what we stated in the
Interim Final Rule related to how costs would be estimated. “This interim final rule
estimates the costs commercial vendors, open source developers, and relevant Federal
agencies will incur to prepare Complete EHRs and EHR Modules to be tested and
certified to adopted standards, implementation specifications, and certification criteria.
The Medicare and Medicaid EHR Incentive Programs proposed rule estimates the
impacts related to the actions taken by eligible professionals or eligible hospitals to
become meaningful users, including purchasing or self-developing Complete EHRs or
EHR Modules. The HIT Certification Programs proposed rule estimates the testing and
certification costs for Complete EHRs and EHR Modules.” Accordingly, we disagree
with the commenter who contended that our estimates were too simplistic and linear. We
believe that in the absence of any additional data or an alternative model (which no
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