ehr onc final certification - Department of Health Care Services

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EHR or EHR Module: 1) already includes the capability; 2) includes some aspect of the capability which would need to be updated; 3) does not currently include the capability at all. We believe it is reasonable to estimate that it will cost somewhere between $10,000 and $250,000 per certification criterion to prepare a Complete EHR for testing and certification taking into account the factors identified directly above. We have used this per certification criterion range as the basis for our low and high cost range estimates. For the ease of our calculations, we have rounded to “40” the number of certification criteria that the Secretary is adopting. For Table 1 we have made the following assumptions based on our understanding of the capabilities present in previously CCHIT-certified-EHRs: 1) in general, Complete EHR developers who previously obtained a CCHIT certification for their EHR technology will possess a Complete EHR that will meet approximately 75% of the adopted certification criteria and, as a result, these Complete EHR developers may need to make more comprehensive adjustments to their Complete EHRs in order to prepare the Complete EHRs to be tested and certified to the remaining 25% of the certification criteria adopted by the Secretary; 2) the average low and high per certification criterion cost for ambulatory EHRs previously certified by CCHIT which need to be prepared for testing and certification will be $50,000 and $150,000, respectively; and 3) the average low and high per certification criterion cost for previously CCHIT-certified inpatient EHRs to be prepared for testing and certification will be $75,000 and $200,000, respectively. Table 1. Estimated One-Time Costs for Complete EHR Developers to Prepare Previously CCHIT-Certified-EHRs to be Tested and Certified (3-year-period) – Totals Rounded Number One Time Cost Per Total Cost for All EHRs over 3-year Type Prepared EHR ($M) Period ($M) Page 196 of 228
for Certification Low High Page 197 of 228 Midpoint Low High Mid-point 2008 Ambulatory CCHIT- Certified- EHR 65 $0.50 $1.5 $1.0 $32.5 $97.5 $65.0 2007/2008 Inpatient CCHIT- Certified- EHR 15 $0.75 $2.0 $1.38 $11.25 $30.0 $20.63 Total 80 $43.75 $127.50 $85.63 The second type of cost we estimate includes the costs that we expect for CCHIT- certified ambulatory EHRs certified prior to 2008 (“out-of-date CCHIT-Certified-EHRs”) and never previously CCHIT-certified-EHRs to be prepared to be tested and certified as Complete EHRs rather than as EHR Modules. 14 We assume the EHR technology that falls into this category may require more extensive changes than previously CCHIT- certified-EHRs identified in Table 1. Again, we have estimated low and high preparation cost ranges. We assume that there will be very little growth in the Complete EHR market due to the market share 15 represented by the previously CCHIT-certified-EHRs included in Table 1 and the upfront costs required to bring a Complete EHR to market. As a result, we expect there to be 8 and 5 Complete EHRs (for use by eligible professionals and eligible hospitals, respectively) prepared to be tested and certified to all of the applicable certification criteria adopted by the Secretary. 16 14 CCHIT began testing and certifying inpatient EHRs in 2007 and we assume that all of those EHRs are included in Table 1 which is why they are not included in this discussion. 15 http://www.cchit.org/about -- “...EHR products certified by mid-2009, representing over 75% of the marketplace.” 16 This estimate is premised in part on the fact that IHS’s RPMS EHR was not included in Table 1 and that it will be preparing the RPMS EHR as a Complete EHR to meet the applicable certification criteria adopted by the Secretary for both ambulatory and inpatient settings.
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DEPARTMENT OF HEALTH AND HUMAN SERV
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HHS Department of Health and Human
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5. Definition of Qualified EHR 6. D
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technology. Section 3004(b)(1) of t
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esolve identified technical challen
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Some commenters appear to have misi
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efficiencies and desired quality im
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codes must be used “inside” an
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not necessarily have applied to our
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3. Definition of Implementation Spe
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program established by the National
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criteria adopted by the Secretary a
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Comment. In the context of the defi
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y the certification criteria for a
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commenters asked whether we meant t
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adopted by the Secretary. The secon
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Response. We would like to make cle
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Response. In the Interim Final Rule
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could be a health care professional
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standard for certain purposes. In s
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e voluntary and would not be requir
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already existing regulatory require
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setting). We also include, where ap
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clarification on why the number of
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more clearly specify this capabilit
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Response. While we do not require t
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that check, the functionality show
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Response. The comments are correct
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enable the user to electronically r
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longitudinal care, or whether the E
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EHR and EHR Module developers to pr
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suggestions for different age range
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Record smoking status for patients
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23) during the EHR reporting period
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laboratory test results are receive
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commenters reasoned that because a
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laboratory test results to be elect
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or outreach Generate patient lists.
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months). We believe that these revi
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that the PQRI 2009 Registry XML spe
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To better align this certification
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the capability specified by the cer
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vendors were unwilling or unable to
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the concerns expressed by some comm
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Page 89 of 228 electronically compa
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(1) The standard (and applicable im
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for the purposes of demonstrating c
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Guide for Immunization Messaging Re
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Response. We clarify for commenters
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serve as a limiting factor, however
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Page 101 of 228 Unchanged Comment.
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Comment. One commenter suggested th
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Response. We appreciate the thought
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Complete EHRs or EHR Modules design
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Response. We disagree. As stated ab
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Response. As discussed above, we ha
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SHA-1 and other secure hash algorit
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misinterpreted our example and stat
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Other commenters also expressed con
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eferenced in FIPS 140-2 Annex A, wh
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of the most secure encryption algor
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the disclosure was made (recipient)
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Use CPOE for medication orders dire
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equire EHRs to build custom interfa
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esult, we do not believe that this
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was needed before RxNorm could be a
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• MDDB - Medi-Span Master Drug Da
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Response. We do not believe that it
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Send reminders to patients per pati
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specified data elements and CMS’s
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what would qualify as a "response."
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Comment. A commenter recommended th
Page 145 and 146: in accordance with one of the adopt
Page 147 and 148: Comments. Many commenters suggested
Page 149 and 150: flexibility in this certification c
Page 151 and 152: productive, confusing, time-consumi
Page 153 and 154: include in this initial set. Accord
Page 155 and 156: to the HITSP C32 implementation spe
Page 157 and 158: Response. Again, we do not believe
Page 159 and 160: e achieved without these and recomm
Page 161 and 162: electronically record, store, retri
Page 163 and 164: EHRs and EHR Modules designed for a
Page 165 and 166: §170.205(a)(2)(iii); and (v) The s
Page 167 and 168: Response. We disagree, as doing so
Page 169 and 170: Dental Terminology as a condition o
Page 171 and 172: However, we do not preclude Complet
Page 173 and 174: ability of CCD and CCR to support t
Page 175 and 176: ability to receive these reports. M
Page 177 and 178: commenters acknowledged and express
Page 179 and 180: a meaningful use objective they wou
Page 181 and 182: CMS and ONC had worked together to
Page 183 and 184: The eligible professional or eligib
Page 185 and 186: EHR technology with the needs of us
Page 187 and 188: The RFA requires agencies to analyz
Page 189 and 190: values seemed low and that the gap
Page 191 and 192: commenter provided), our assumption
Page 193 and 194: absolute low we estimated for a per
Page 195: number of previously CCHIT-certifie
Page 199 and 200: Finally, the third type of cost we
Page 201 and 202: 2012 15% $10.10 $30.80 $20.45 3-Yea
Page 203 and 204: The RFA requires agencies to analyz
Page 205 and 206: The Office of Management and Budget
Page 207 and 208: The standards and implementation sp
Page 209 and 210: The Secretary adopts the following
Page 211 and 212: any edition other than that specifi
Page 213 and 214: (e) Regenstrief Institute, Inc., LO
Page 215 and 216: 4. Revise subpart C to read as foll
Page 217 and 218: smoker; current some day smoker; fo
Page 219 and 220: (2) Generate audit log. Enable a us
Page 221 and 222: (3) Medication allergy list; (4) De
Page 223 and 224: §170.205(a)(1) or §170.205(a)(2).
Page 225 and 226: (d) Electronic copy of health infor
Page 227 and 228: specifications) specified in §170.
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