ehr onc final certification - Department of Health Care Services

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§170.302(j) - Check insurance eligibility and §170.302(k) - Submit claims Meaningful Use Stage 1 Objective Removed from final rule Meaningful Use Stage 1 Objective Removed from final rule Meaningful Use Stage 1 Measure Removed from final rule Meaningful Use Stage 1 Measure Removed from final rule Page 84 of 228 Certification Criterion Interim Final Rule Text: Enable a user to electronically record and display patients’ insurance eligibility, and submit insurance eligibility queries to public or private payers and receive an eligibility response in accordance with the applicable standards and implementation specifications specified in §170.205(d)(1) or (2). Final Rule Text: Removed Certification Criterion Interim Final Rule Text: Enable a user to electronically submit claims to public or private payers in accordance with the standard and implementation specifications specified in §170.205(d)(3). Final Rule Text: Removed Comments. Many commenters recommended that the certification criteria for administrative transactions be removed because they considered the administrative capabilities that we required to be outside of the scope of an electronic health record and stated further that their inclusion did not align with the HIT industry’s common view of what constituted EHR technology. A large number of commenters conveyed specific challenges including: these functions are usually handled by practice management systems which generally are separate from an EHR, although on occasion some vendors include these functionalities in their EHRs; practice management systems adoption is already very high and requiring certification for these products would be unnecessary and burdensome, given the wide variety and number of vendors and significant potential for increasing costs for providers; providers interested in achieving meaningful use would have to abandon a working practice management system if their practice management
vendors were unwilling or unable to get certified; and many providers currently use clearinghouses to convert paper claims into electronic claims to submit to CMS and other payers. Several commenters recommended retaining the administrative transactions certification criteria because it would eventually reduce administrative costs across the health care system. Many commenters requested that we clarify several aspects of these certification criteria while some other commenters noted that significant progress has been made in using electronic eligibility inquires and claims transactions outside of an EHR context. Those commenters expressed concern that the inclusion of administrative transaction capability in this rule would create confusion, ambiguity, and potentially duplicate efforts. A couple of commenters noted that some payers do not accept electronic claims and eligibility checks. One commenter expressly noted that including the administrative functionalities would decrease innovation by creating a large barrier to entry for EHR innovators. Finally, a couple of commenters noted that health care providers would face significant challenges in the transition to ASC X12N 5010 and ICD-10 and lost productivity. Response. In concert with CMS, we have considered commenters’ rationale for and against the inclusion of these certification criteria. We have tried to summarize above several technical and programmatic challenges commenters identified if administrative transaction capability were included within the certification requirements. Due to the removal of these objectives from the meaningful use Stage 1 requirements, we do not believe that it would be appropriate to continue to require, as a condition of certification, that Complete EHRs and EHR Modules include these capabilities. Page 85 of 228
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DEPARTMENT OF HEALTH AND HUMAN SERV
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HHS Department of Health and Human
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5. Definition of Qualified EHR 6. D
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technology. Section 3004(b)(1) of t
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esolve identified technical challen
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Some commenters appear to have misi
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efficiencies and desired quality im
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codes must be used “inside” an
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not necessarily have applied to our
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3. Definition of Implementation Spe
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program established by the National
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criteria adopted by the Secretary a
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Comment. In the context of the defi
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y the certification criteria for a
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commenters asked whether we meant t
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adopted by the Secretary. The secon
Page 33 and 34: Response. We would like to make cle
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
Page 83: the capability specified by the cer
Page 87 and 88: the concerns expressed by some comm
Page 89 and 90: Page 89 of 228 electronically compa
Page 91 and 92: (1) The standard (and applicable im
Page 93 and 94: for the purposes of demonstrating c
Page 95 and 96: Guide for Immunization Messaging Re
Page 97 and 98: Response. We clarify for commenters
Page 99 and 100: serve as a limiting factor, however
Page 101 and 102: Page 101 of 228 Unchanged Comment.
Page 103 and 104: Comment. One commenter suggested th
Page 105 and 106: Response. We appreciate the thought
Page 107 and 108: Complete EHRs or EHR Modules design
Page 109 and 110: Response. We disagree. As stated ab
Page 111 and 112: Response. As discussed above, we ha
Page 113 and 114: SHA-1 and other secure hash algorit
Page 115 and 116: misinterpreted our example and stat
Page 117 and 118: Other commenters also expressed con
Page 119 and 120: eferenced in FIPS 140-2 Annex A, wh
Page 121 and 122: of the most secure encryption algor
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Page 125 and 126: Use CPOE for medication orders dire
Page 127 and 128: equire EHRs to build custom interfa
Page 129 and 130: esult, we do not believe that this
Page 131 and 132: was needed before RxNorm could be a
Page 133 and 134: • MDDB - Medi-Span Master Drug Da
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Response. We do not believe that it
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Send reminders to patients per pati
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specified data elements and CMS’s
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what would qualify as a "response."
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Comment. A commenter recommended th
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in accordance with one of the adopt
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Comments. Many commenters suggested
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flexibility in this certification c
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productive, confusing, time-consumi
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include in this initial set. Accord
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to the HITSP C32 implementation spe
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Response. Again, we do not believe
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e achieved without these and recomm
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electronically record, store, retri
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EHRs and EHR Modules designed for a
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§170.205(a)(2)(iii); and (v) The s
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Response. We disagree, as doing so
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Dental Terminology as a condition o
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However, we do not preclude Complet
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ability of CCD and CCR to support t
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ability to receive these reports. M
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commenters acknowledged and express
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a meaningful use objective they wou
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CMS and ONC had worked together to
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The eligible professional or eligib
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EHR technology with the needs of us
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The RFA requires agencies to analyz
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values seemed low and that the gap
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commenter provided), our assumption
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absolute low we estimated for a per
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number of previously CCHIT-certifie
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for Certification Low High Page 197
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Finally, the third type of cost we
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2012 15% $10.10 $30.80 $20.45 3-Yea
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The RFA requires agencies to analyz
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The Office of Management and Budget
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The standards and implementation sp
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The Secretary adopts the following
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any edition other than that specifi
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(e) Regenstrief Institute, Inc., LO
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4. Revise subpart C to read as foll
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smoker; current some day smoker; fo
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(2) Generate audit log. Enable a us
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(3) Medication allergy list; (4) De
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§170.205(a)(1) or §170.205(a)(2).
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(d) Electronic copy of health infor
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specifications) specified in §170.
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