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ehr onc final certification - Department of Health Care Services

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interfaces between “HIT systems” may be critical to the functionality <strong>of</strong> the separate<br />

systems, but they themselves would not be EHR Modules.<br />

In those circumstances in which an interface or other s<strong>of</strong>tware program is an<br />

integral component <strong>of</strong> an EHR Module without which it would not be able to be tested<br />

and certified, then such interface or other s<strong>of</strong>tware program, though not itself an EHR<br />

Module, would function as a critical piece <strong>of</strong> the overall EHR Module presented for<br />

testing and <strong>certification</strong>. For example, a s<strong>of</strong>tware program that would permit an eligible<br />

pr<strong>of</strong>essional or eligible hospital to electronically exchange health information with other<br />

eligible pr<strong>of</strong>essionals or eligible hospitals could be tested and certified as an EHR<br />

Module, if it provides the capability to electronically exchange health information<br />

according to standards adopted by the Secretary. In this example, whatever comprises<br />

the s<strong>of</strong>tware program would be considered part <strong>of</strong> the EHR Module that is tested and<br />

certified.<br />

Finally, in situations where an eligible pr<strong>of</strong>essional or eligible hospital believes<br />

that it has multiple HIT systems that would each meet the definition <strong>of</strong> EHR Module, we<br />

suggest that the eligible pr<strong>of</strong>essional or eligible hospital evaluate whether these systems<br />

could be combined with other systems to constitute a Complete EHR. If they are capable<br />

<strong>of</strong> being combined to form a Complete EHR, it may be more expeditious and beneficial<br />

for an eligible pr<strong>of</strong>essional or eligible hospital to simply seek Complete EHR testing and<br />

<strong>certification</strong>.<br />

Comments. A few commenters requested that we clarify how EHR Modules<br />

would be tested and certified to adopted privacy and security <strong>certification</strong> criteria. Other<br />

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