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ehr onc final certification - Department of Health Care Services

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for the purposes <strong>of</strong> demonstrating compliance with this <strong>certification</strong> criterion would be<br />

appropriate.<br />

Comment. One commenter recommended that we revise the <strong>certification</strong><br />

criterion combined with associated standards to state “For the purposes <strong>of</strong> electronically<br />

submitting information to immunization registries Certified EHR Technology must be<br />

capable <strong>of</strong> using a certified EHR module or portal provided by a state immunization<br />

registry which is capable <strong>of</strong> submitting and retrieving coded immunization information or<br />

capable <strong>of</strong> using HL7 2.3.1 or HL7 2.5.1 as a content exchange standard and the CDC<br />

maintained HL7 standard code set CVX—Vaccines Administered as the vocabulary<br />

standard.” The basis for this commenter’s suggestion was that providers in its state link<br />

to the state’s immunization module through EHRs and that all immunization data are<br />

stored immediately in the state’s registry. The commenter further clarified that since the<br />

data resides in the state registry natively, there is no need to transmit this information.<br />

Response. In light <strong>of</strong> this commenter’s suggestion, we have revised the<br />

<strong>certification</strong> criterion to replace the word “transmit” with “submit” to better align this<br />

<strong>certification</strong> criterion with the meaningful use objective and measure. We believe that<br />

submission <strong>of</strong> immunization data would encompass this commenter’s existing method.<br />

Comment. One commenter stated that they believed the use <strong>of</strong> CVX is neither<br />

mature nor widespread.<br />

Response. We disagree. Our information indicates that CVX codes are widely<br />

used for reporting to immunization registries.<br />

Comment. Some commenters identified implementation specifications that are<br />

available for the standards we had adopted for transmitting immunization information. A<br />

Page 93 <strong>of</strong> 228

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