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
adopted by the Secretary, and the resultant combination also meets the requirements included in the definition of a Qualified EHR. As discussed in the Temporary Certification Program final rule, a pre-coordinated integrated bundle of EHR Modules would fall under the second definition of Certified EHR Technology, although each EHR Module of the bundle would be tested and certified at the same time rather than separately. Therefore, provided that a proper combination of EHR Modules has been created, combinations of EHR Modules could be tested and certified either at the same time or at separate times, to meet the definition of Certified EHR Technology. Finally, we believe that commenter suggestions to revise the definition of Certified EHR Technology to reference specific certification criteria are misguided. The definition, regardless of the certification criteria that must be included in a Complete EHR or combination of EHR Modules, must be able to accommodate changes in certification criteria over time. Accordingly we believe that the final definition meets this intended goal and conveys a clear meaning. Comments. Some commenters appeared to interpret our definition as providing that EHR Modules must be used to meet the definition of Certified EHR Technology. Of these commenters, some requested that we clarify whether health care providers would be required to obtain certification of EHR Modules that no vendors support. Other commenters asked whether non-certified “EHR modules” could be used in combination with a Complete EHR or in combination with EHR Modules that are used to meet the definition of Certified EHR Technology. Page 32 of 228
Response. We would like to make clear that eligible professionals and eligible hospitals are not required to use EHR Modules in order to meet the definition of Certified EHR Technology. The use of EHR Modules is completely voluntary and provides an alternate avenue for eligible professionals and eligible hospitals who seek to implement more customized HIT solutions while still meeting the definition of Certified EHR Technology. Commenters who expressed concerns about their responsibility for seeking certification for EHR Modules for which no vendor supports did not provide specific examples, and we are uncertain as to the basis for their concerns. Regardless, we reiterate that the use of EHR Modules is voluntary and we believe that most eligible professionals and eligible hospitals that are adopting HIT for the first time will have a variety of Complete EHRs available from which to choose. We also clarify that only those EHR Modules that provide capabilities necessary to meet the definition of Certified EHR Technology will need to be tested and certified. That being said, eligible professionals and eligible hospitals are free to utilize any other type of HIT to complement or in combination with Certified EHR Technology, including HIT that provides capabilities for other purposes not related to meaningful use. Comments. Some commenters suggested that our definition was too broad. Most of these commenters argued that we should permit eligible professionals to adopt only Complete EHRs and EHR Modules that were certified as including only those capabilities applicable to their specialty or practice. In other words, these commenters sought for the definition of Certified EHR Technology to be interpreted in such a way as to permit different specialty-oriented variations of Certified EHR Technology to exist. Page 33 of 228
- Page 1 and 2: DEPARTMENT OF HEALTH AND HUMAN SERV
- Page 3 and 4: HHS Department of Health and Human
- Page 5 and 6: 5. Definition of Qualified EHR 6. D
- Page 7 and 8: technology. Section 3004(b)(1) of t
- Page 9 and 10: esolve identified technical challen
- Page 11 and 12: Some commenters appear to have misi
- Page 13 and 14: efficiencies and desired quality im
- Page 15 and 16: codes must be used “inside” an
- Page 17 and 18: not necessarily have applied to our
- Page 19 and 20: 3. Definition of Implementation Spe
- Page 21 and 22: program established by the National
- Page 23 and 24: criteria adopted by the Secretary a
- Page 25 and 26: Comment. In the context of the defi
- Page 27 and 28: y the certification criteria for a
- Page 29 and 30: commenters asked whether we meant t
- Page 31: adopted by the Secretary. The secon
- Page 35 and 36: Response. In the Interim Final Rule
- Page 37 and 38: could be a health care professional
- Page 39 and 40: standard for certain purposes. In s
- Page 41 and 42: e voluntary and would not be requir
- Page 43 and 44: already existing regulatory require
- Page 45 and 46: setting). We also include, where ap
- Page 47 and 48: clarification on why the number of
- Page 49 and 50: more clearly specify this capabilit
- Page 51 and 52: Response. While we do not require t
- Page 53 and 54: that check, the functionality show
- Page 55 and 56: Response. The comments are correct
- Page 57 and 58: enable the user to electronically r
- Page 59 and 60: longitudinal care, or whether the E
- Page 61 and 62: EHR and EHR Module developers to pr
- Page 63 and 64: suggestions for different age range
- Page 65 and 66: Record smoking status for patients
- Page 67 and 68: 23) during the EHR reporting period
- Page 69 and 70: laboratory test results are receive
- Page 71 and 72: commenters reasoned that because a
- Page 73 and 74: laboratory test results to be elect
- Page 75 and 76: or outreach Generate patient lists.
- Page 77 and 78: months). We believe that these revi
- Page 79 and 80: that the PQRI 2009 Registry XML spe
- Page 81 and 82: To better align this certification
Response. We would like to make clear that eligible pr<strong>of</strong>essionals and eligible<br />
hospitals are not required to use EHR Modules in order to meet the definition <strong>of</strong> Certified<br />
EHR Technology. The use <strong>of</strong> EHR Modules is completely voluntary and provides an<br />
alternate avenue for eligible pr<strong>of</strong>essionals and eligible hospitals who seek to implement<br />
more customized HIT solutions while still meeting the definition <strong>of</strong> Certified EHR<br />
Technology. Commenters who expressed c<strong>onc</strong>erns about their responsibility for seeking<br />
<strong>certification</strong> for EHR Modules for which no vendor supports did not provide specific<br />
examples, and we are uncertain as to the basis for their c<strong>onc</strong>erns. Regardless, we<br />
reiterate that the use <strong>of</strong> EHR Modules is voluntary and we believe that most eligible<br />
pr<strong>of</strong>essionals and eligible hospitals that are adopting HIT for the first time will have a<br />
variety <strong>of</strong> Complete EHRs available from which to choose.<br />
We also clarify that only those EHR Modules that provide capabilities necessary<br />
to meet the definition <strong>of</strong> Certified EHR Technology will need to be tested and certified.<br />
That being said, eligible pr<strong>of</strong>essionals and eligible hospitals are free to utilize any other<br />
type <strong>of</strong> HIT to complement or in combination with Certified EHR Technology, including<br />
HIT that provides capabilities for other purposes not related to meaningful use.<br />
Comments. Some commenters suggested that our definition was too broad.<br />
Most <strong>of</strong> these commenters argued that we should permit eligible pr<strong>of</strong>essionals to adopt<br />
only Complete EHRs and EHR Modules that were certified as including only those<br />
capabilities applicable to their specialty or practice. In other words, these commenters<br />
sought for the definition <strong>of</strong> Certified EHR Technology to be interpreted in such a way as<br />
to permit different specialty-oriented variations <strong>of</strong> Certified EHR Technology to exist.<br />
Page 33 <strong>of</strong> 228
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