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ehr onc final certification - Department of Health Care Services

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Page 89 <strong>of</strong> 228<br />

electronically compare two or more medication<br />

lists.<br />

Comments. Many commenters suggested that for this <strong>certification</strong> criterion we<br />

clarify whether we intended for the process <strong>of</strong> medication rec<strong>onc</strong>iliation to be automatic<br />

or to support an eligible pr<strong>of</strong>essional or eligible hospital in performing this task. Many<br />

saw the former as a potential risk to patient safety. Although several different reasons<br />

were given, many commenters recommended that we revise the <strong>certification</strong> criterion to<br />

indicate that two or more medication lists be simultaneously displayed in order to permit<br />

an eligible pr<strong>of</strong>essional or eligible hospital to then rec<strong>onc</strong>ile the medication lists.<br />

Response. We have reviewed commenters’ c<strong>onc</strong>erns and intend to clarify the<br />

language in this <strong>certification</strong> criterion. We recognize that the technical foundation and<br />

safety checks are not currently in place for automated medication rec<strong>onc</strong>iliation. We did<br />

not intend to imply that automated rec<strong>onc</strong>iliation needed to occur through our use <strong>of</strong> the<br />

word “electronically.” We used the term “electronically” to express our expectation that<br />

eligible pr<strong>of</strong>essionals and eligible hospitals would be able to use Certified EHR<br />

Technology to complete this task. Accordingly, we have revised this <strong>certification</strong><br />

criterion to require that Certified EHR Technology be capable <strong>of</strong> providing a user with<br />

the ability to electronically compare two or more medication lists (e.g., between an<br />

externally provided medication list and the current medication list in Certified EHR<br />

Technology). We expect that this could be done in a number <strong>of</strong> ways and we do not want<br />

to preclude Complete EHR and EHR Module developers from innovating, provided that<br />

the desired outcome is reached. For example, a user could be presented with two<br />

electronic lists side-by-side and move medications from one list to the other and then<br />

select the <strong>final</strong> current list. Alternatively, a user could view one list and two PDFs <strong>of</strong>

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