ehr onc final certification - Department of Health Care Services

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.
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