ehr onc final certification - Department of Health Care Services

that the PQRI 2009 Registry XML specification, a more recent version of the standards
we adopted in the Interim Final Rule is a suitable replacement for 2008 version, and
accordingly, we have adopted the 2009 version in its place. We believe this revision
should assuage some commenters’ concerns about the obsolescence of the adopted
standard and reduce concerns that a wholly different standard would be adopted in the
near future. If adopting a different standard for Certified EHR Technology becomes
necessary, we would do so only after engaging in subsequent rulemaking.
Comments. A few commenters stated that many of the clinical quality measures
proposed by CMS do not have electronic specifications and contended that it would be
difficult for any vendor to have embedded these measures in their EHR products in a
timely manner. But, these same commenters stated that when the specifications become
available, that HHS should ensure through the certification process that the products are
capable of generating accurate data. Many commenters expressed concerns that the
certification criterion was too vague or too broad (because it implicitly referenced all of
the quality measures CMS had proposed). Some of the commenters recommended that
this certification criterion be removed, while others recommended that it focus on a
subset of measures in order to constrain the amount of electronic measure specifications a
Complete EHR or EHR Module developer would need to address in order to be certified.
At least one of these latter commenters indicated that our adopted certification criteria
created uncertainty for Complete EHR and EHR Module Developers. This commenter
asked that we clarify what clinical quality measures would need to be tested in order to
satisfy this certification criterion and if there would be a baseline for eligible hospital
measures as well as some identified core set of measures for eligible professionals.
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