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ehr onc final certification - Department of Health Care Services

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Response. While we do not require that the option to disable drug-drug and drug-<br />

allergy checks be removed as a condition <strong>of</strong> <strong>certification</strong>, we note that in order for an<br />

eligible pr<strong>of</strong>essional or eligible hospital to become a meaningful user <strong>of</strong> Certified EHR<br />

Technology this capability must be enabled.<br />

Comments. Several commenters noted that the NCPDP Formulary and Benefits<br />

standard is not used in an inpatient setting. The commenters consequently requested<br />

clarification as to how the standard can be used in an inpatient setting. Some <strong>of</strong> the<br />

commenters noted that for inpatient settings, hospitals typically relied on their own<br />

formularies for performing the types <strong>of</strong> checks specified. Another commenter requested<br />

clarification whether the correct content exchange standard was National Council for<br />

Prescription Drug Programs (NCPDP) Formulary and Benefits Standard version 1.0 and<br />

that if it was, the commenter recommended its adoption. Another commenter noted that<br />

some State Medicaid formularies are not yet available via nationwide e-prescribing<br />

networks and recommended that ONC encourage the implementation <strong>of</strong> State Medicaid<br />

formularies within the NCPDP Formulary and Benefits Standard via a nationwide e-<br />

prescribing network.<br />

Response. We agree with those commenters who identified the inconsistency <strong>of</strong><br />

applying the Formulary and Benefits standard to the inpatient setting. Because the CMS<br />

proposed meaningful use objectives applied to both eligible pr<strong>of</strong>essionals and eligible<br />

hospitals, we did not make the distinction as to when a Complete EHR or EHR Module<br />

would need to include the Formulary and Benefits standard. However, in light <strong>of</strong> these<br />

comments and to support the <strong>final</strong> meaningful use measure, we have determined that it<br />

would be appropriate to adopt a more general <strong>certification</strong> criterion that would be<br />

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