ehr onc final certification - Department of Health Care Services

Architecture (QRDA) and the PQRI XML Registry specification in this rulemaking and
move to a single standard in the next rulemaking. Other commenters recommended that
QRDA not be adopted in this rulemaking. Several commenters suggested that an
implementation specification for eligible hospitals be created if we intend to continue to
require that quality measure be reported in the PQRI Registry XML format. One
commenter expressed a concern that if the PQRI 2008 Registry XML standard is
maintained as the adopted standard that there is a danger that the certification Complete
EHR and EHR Module developers obtain may become obsolete before Stage 1 has run its
course. Finally, a couple of commenters suggested that ONC consider deferring the
naming of a standard for submission of clinical quality measures until Stage 2 and instead
only require what is necessary to support clinical quality measure submission in Stage 1.
Response. Many commenters misinterpreted our intent with respect to the
adoption of the PQRI 2008 Registry XML specification as the standard for electronically
submitting quality reporting data to CMS. Presently, CMS requires the submission of
aggregate, summary level data for the purposes of meaningful use and not data at the
patient-specific level. It is our understanding that the PQRI 2008 Registry XML
specification is capable of serving as the “envelope” for aggregate, summary level data.
Accordingly, we do not believe that, as some commenters suggested, an eligible
hospital’s familiarity with the PQRI program is relevant to the adoption of this standard
for this specified purpose. Nor do we believe that a specific implementation of this
standard is necessary for hospital settings as the standard’s purpose and the type of data it
will transmit to CMS will be the same – aggregate, summary level data. Through recent
discussions with CMS since the publication of the Interim Final Rule we have determined
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