ehr onc final certification - Department of Health Care Services

applicable to both Complete EHRs and EHR Modules designed for ambulatory and
inpatient settings. Accordingly, we have removed any reference to a particular standard
because an eligible professional or eligible hospital that does not have external access to a
drug formulary would be able to satisfy this meaningful use measure by checking an
internally managed drug formulary. Although the Formulary and Benefits standard is no
longer required as a condition of certification, we note that eligible professionals who
seek to comply with the electronic prescribing requirements associated with Medicare
Part D eligible individuals will need to use this standard as they do today. Additionally,
we do not agree that it is within the scope of this rulemaking to address State Medicaid
Agencies’ participation in nationwide e-prescribing networks.
Comments. Many commenters noted that the drug-formulary requirement should
not apply to Complete EHRs and EHR Modules designed for an inpatient setting because
there was no proposed requirement for meaningful use Stage 1 for eligible hospitals to
electronically prescribe. Many of the commenters recommended removing this as a
requirement for eligible hospitals while retaining it with the criteria for eligible
professionals. A few commenters specifically recommended adding it to the criterion for
electronic prescribing. Several commenters recommended that if the requirement were
kept for hospitals it should be written as a separate criterion to address the query of a
hospital’s drug formulary during the order entry process and not the NCPDP Formulary
and Benefits standard. A commenter stated that current industry practice among vendors
of EHR technology is to provide a “generic” national formulary rather than the formulary
for a particular plan. The commenter recommended that the functionality require that a
user actually perform an eligibility check before access is provided and, in response to
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