ehr onc final certification - Department of Health Care Services
ehr onc final certification - Department of Health Care Services ehr onc final certification - Department of Health Care Services
couple of these commenters specifically recommended using implementation specifications that would identify message types necessary for transmissions to immunization registries. Commenters also suggested using the CDC’s implementation guides, and explicitly recommended that we adopt the CDC public health information network (PHIN) implementation guide version 2.2 associated with HL7 2.3.1 for the transmission of immunization information and the CDC implementation guide as well as the implementation guide associated with HL7 2.5.1. Response. In the Interim Final Rule, we expressed our interest in receiving public comment on whether there were additional implementation specifications that we should adopt. We also noted that we would consider adopting implementation specifications for any or all of the standards adopted in the Interim Final Rule. After further consideration of commenters’ recommendations and consultation with the CDC, we agree with these commenters and believe that adopting implementation specifications for the transmission of immunization information would benefit EHR technology developers and users. Moreover, given commenters’ general requests for greater specificity and our stated goal of greater interoperability, we believe that it would be appropriate to adopt the following implementation specifications for the submission of immunization data. For HL7 2.3.1 we have adopted the “Implementation Guide for Immunization Data Transactions using Version 2.3.1 of the Health Level Seven (HL7) Standard Protocol, Implementation Guide Version 2.2.” We are aware that this implementation specification has been successfully adopted numerous times in various contexts since its publication four years ago and do not believe that it will be burdensome for Complete EHR and EHR Module developers to implement these specifications. For HL7 2.5.1, we have adopted the “Implementation Page 94 of 228
Guide for Immunization Messaging Release 1.0.” This implementation specification represents the collaborative effort of the American Immunization Registry Association (AIRA) and the CDC. We have also consulted with CDC, and the CDC confirms the appropriateness and supports the usage of these implementation specifications in this context. We encourage migration to this newer implementation specification and believe that it will likely advance interoperability across the country and improve query capabilities. Comment. A commenter recommended that we clarify that the certification criterion should be limited to verifying the ability of the system to record, retrieve, and transmit immunization information. Response. The purpose of testing and certifying a Complete EHR or EHR Module to this certification criterion is to verify that it can perform the capabilities included in the certification criterion. Comment. A couple of commenters strongly supported the transmission of immunization data to state and local immunization registries but requested that the data requirements be expanded to include the transmission of information regarding diseases such as cystic fibrosis to pediatric registries. Response. Presently, we do not believe that it is necessary or appropriate to expand this certification criterion in this manner. We emphasize, though, that this should not preclude eligible professionals or eligible hospitals from using Certified EHR Technology to submit other types of information as medically appropriate and if the recipient of the information is capable of receiving the data. Page 95 of 228
- 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 and 84: the capability specified by the cer
- Page 85 and 86: vendors were unwilling or unable to
- 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: for the purposes of demonstrating c
- 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
- Page 123 and 124: the disclosure was made (recipient)
- 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
- Page 135 and 136: Response. We do not believe that it
- Page 137 and 138: Send reminders to patients per pati
- Page 139 and 140: specified data elements and CMS’s
- Page 141 and 142: what would qualify as a "response."
- Page 143 and 144: Comment. A commenter recommended th
Guide for Immunization Messaging Release 1.0.” This implementation specification<br />
represents the collaborative effort <strong>of</strong> the American Immunization Registry Association<br />
(AIRA) and the CDC. We have also consulted with CDC, and the CDC confirms the<br />
appropriateness and supports the usage <strong>of</strong> these implementation specifications in this<br />
context. We encourage migration to this newer implementation specification and believe<br />
that it will likely advance interoperability across the country and improve query<br />
capabilities.<br />
Comment. A commenter recommended that we clarify that the <strong>certification</strong><br />
criterion should be limited to verifying the ability <strong>of</strong> the system to record, retrieve, and<br />
transmit immunization information.<br />
Response. The purpose <strong>of</strong> testing and certifying a Complete EHR or EHR<br />
Module to this <strong>certification</strong> criterion is to verify that it can perform the capabilities<br />
included in the <strong>certification</strong> criterion.<br />
Comment. A couple <strong>of</strong> commenters strongly supported the transmission <strong>of</strong><br />
immunization data to state and local immunization registries but requested that the data<br />
requirements be expanded to include the transmission <strong>of</strong> information regarding diseases<br />
such as cystic fibrosis to pediatric registries.<br />
Response. Presently, we do not believe that it is necessary or appropriate to<br />
expand this <strong>certification</strong> criterion in this manner. We emphasize, though, that this should<br />
not preclude eligible pr<strong>of</strong>essionals or eligible hospitals from using Certified EHR<br />
Technology to submit other types <strong>of</strong> information as medically appropriate and if the<br />
recipient <strong>of</strong> the information is capable <strong>of</strong> receiving the data.<br />
Page 95 <strong>of</strong> 228
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