ehr onc final certification - Department of Health Care Services

ehr onc final certification - Department of Health Care Services ehr onc final certification - Department of Health Care Services

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interfaces between “HIT systems” may be critical to the functionality of the separate systems, but they themselves would not be EHR Modules. In those circumstances in which an interface or other software program is an integral component of an EHR Module without which it would not be able to be tested and certified, then such interface or other software program, though not itself an EHR Module, would function as a critical piece of the overall EHR Module presented for testing and certification. For example, a software program that would permit an eligible professional or eligible hospital to electronically exchange health information with other eligible professionals or eligible hospitals could be tested and certified as an EHR Module, if it provides the capability to electronically exchange health information according to standards adopted by the Secretary. In this example, whatever comprises the software program would be considered part of the EHR Module that is tested and certified. Finally, in situations where an eligible professional or eligible hospital believes that it has multiple HIT systems that would each meet the definition of EHR Module, we suggest that the eligible professional or eligible hospital evaluate whether these systems could be combined with other systems to constitute a Complete EHR. If they are capable of being combined to form a Complete EHR, it may be more expeditious and beneficial for an eligible professional or eligible hospital to simply seek Complete EHR testing and certification. Comments. A few commenters requested that we clarify how EHR Modules would be tested and certified to adopted privacy and security certification criteria. Other Page 28 of 228

commenters asked whether we meant to allow for there to be EHR Modules that provided only privacy and security capabilities. Response. These comments pertain to the certification programs rule, and are outside of the scope of this rule. We therefore respond to these comments in the Temporary Certification Program final rule (75 FR 36158). 8. Definition of Certified EHR Technology Comments. Multiple commenters commended ONC for recognizing the need to certify EHR Modules and enabling certified EHR Modules to be used in combination to meet the definition of Certified EHR Technology. These commenters noted that this approach makes it clear that eligible professionals and eligible hospitals will have the flexibility to select certified EHR modules that are the most useful to them, and can achieve meaningful use either with combinations of certified HIT or a single EHR system. However, some commenters mentioned that the definition is unnecessarily ambiguous, and subject to possible alternative interpretations. Some commenters also commented on certain statements in the preamble regarding EHR Modules and queried how a proper combination of EHR Modules could be used to meet the definition of Certified EHR Technology. Other commenters, while acknowledging that adopted certification criteria will determine in part what constitutes Certified EHR Technology, urged ONC to revise the definition to include only patient care functionality. Finally, a few commenters offered specific word changes for the definition to improve its clarity. Response. In the Interim Final Rule, we defined Certified EHR Technology to mean “a Complete EHR or a combination of EHR Modules, each of which: (1) Meets the requirements included in the definition of a Qualified EHR; and (2) Has been tested and Page 29 of 228

commenters asked whether we meant to allow for there to be EHR Modules that provided<br />

only privacy and security capabilities.<br />

Response. These comments pertain to the <strong>certification</strong> programs rule, and are<br />

outside <strong>of</strong> the scope <strong>of</strong> this rule. We therefore respond to these comments in the<br />

Temporary Certification Program <strong>final</strong> rule (75 FR 36158).<br />

8. Definition <strong>of</strong> Certified EHR Technology<br />

Comments. Multiple commenters commended ONC for recognizing the need to<br />

certify EHR Modules and enabling certified EHR Modules to be used in combination to<br />

meet the definition <strong>of</strong> Certified EHR Technology. These commenters noted that this<br />

approach makes it clear that eligible pr<strong>of</strong>essionals and eligible hospitals will have the<br />

flexibility to select certified EHR modules that are the most useful to them, and can<br />

achieve meaningful use either with combinations <strong>of</strong> certified HIT or a single EHR<br />

system. However, some commenters mentioned that the definition is unnecessarily<br />

ambiguous, and subject to possible alternative interpretations. Some commenters also<br />

commented on certain statements in the preamble regarding EHR Modules and queried<br />

how a proper combination <strong>of</strong> EHR Modules could be used to meet the definition <strong>of</strong><br />

Certified EHR Technology. Other commenters, while acknowledging that adopted<br />

<strong>certification</strong> criteria will determine in part what constitutes Certified EHR Technology,<br />

urged ONC to revise the definition to include only patient care functionality. Finally, a<br />

few commenters <strong>of</strong>fered specific word changes for the definition to improve its clarity.<br />

Response. In the Interim Final Rule, we defined Certified EHR Technology to<br />

mean “a Complete EHR or a combination <strong>of</strong> EHR Modules, each <strong>of</strong> which: (1) Meets the<br />

requirements included in the definition <strong>of</strong> a Qualified EHR; and (2) Has been tested and<br />

Page 29 <strong>of</strong> 228

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