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

dhss.alaska.gov
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10.08.2013 Views

Comment. A commenter recommended including the term “modify” in the certification criterion. Response. We agree, and consistent with our other certification criteria that include the term “modify,” we have added this term. §170.302(n) - Public health surveillance Meaningful Use Stage 1 Objective Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice Meaningful Use Stage 1 Measure Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and follow-up submission if the test is successful (unless none of the public health agencies to which an EP, eligible hospital or CAH submits such information have the capacity to receive the information electronically) Page 96 of 228 Certification Criterion Interim Final Rule Text: Public health surveillance. Electronically record, retrieve, and transmit syndrome-based public health surveillance information to public health agencies in accordance with one of the standards specified in §170.205(g). Final Rule Text: §170.302(l) Public health surveillance. Electronically record, modify, retrieve, and submit syndrome-based public health surveillance information in accordance with the standard (and applicable implementation specifications) specified in §170.205(d)(1) or §170.205(d)(2). Comments. A couple of commenters supported the adoption of certification criteria related to public health reporting. One commenter believed that this certification criterion should be implemented as adopted. Response. We appreciate commenters’ support of this certification criterion. Comment. One commenter recommended that we defer any vocabulary standard for public health reporting and surveillance until a later date. Another commenter expressed concern that we would adopt as a standard, “according to applicable public health agency requirements,” because they thought it could be problematic for hospital systems with facilities in two or more states, as their EHR technology would have to meet whatever standards each state elected to use.

Response. We clarify for commenters that we adopted two content exchange standards for electronic submission to public health agencies for surveillance and reporting. We did not adopt a specific vocabulary standard, nor did we include the phrase one commenter stated that we included. However, we have, consistent with our rationale in the immunization submission certification criterion, removed our reference to “public health agencies” as the recipient of information. Also, consistent with the certification criterion above, we have replaced the term “transmit” with “submit.” Comments. A couple of commenters stated that compliance with HL7 2.5.1 not be included in this adopted set of standards. One commenter suggested HL7 2.5.1 should be adopted in a future rulemaking. Another commenter suggested that HL7 2.3.1 be required for the purposes of certification. Another commenter recommended that the standard be HL7 2.3.1, because in its opinion many public health agencies cannot comply with HL7 2.5.1 while another commenter took the opposite position and recommended HL7 2.5.1. Response. Given the diversity in implementations and public health agencies’ ability to receive information in a given standard, we believe that the flexibility included in this criterion is necessary for the foreseeable future. However, relative to the general comments we received regarding the adoption of implementation specifications for adopted standards, we have adopted the following implementation specifications for HL7 2.5.1: Public Health Information Network HL7 Version 2.5 Message Structure Specification for National Condition Reporting Final Version 1.0 and the Errata and Clarifications National Notification Message Structural Specification. We believe that these implementation specifications provide the additional clarity commenters were Page 97 of 228

Response. We clarify for commenters that we adopted two content exchange<br />

standards for electronic submission to public health agencies for surveillance and<br />

reporting. We did not adopt a specific vocabulary standard, nor did we include the<br />

phrase one commenter stated that we included. However, we have, consistent with our<br />

rationale in the immunization submission <strong>certification</strong> criterion, removed our reference to<br />

“public health agencies” as the recipient <strong>of</strong> information. Also, consistent with the<br />

<strong>certification</strong> criterion above, we have replaced the term “transmit” with “submit.”<br />

Comments. A couple <strong>of</strong> commenters stated that compliance with HL7 2.5.1 not<br />

be included in this adopted set <strong>of</strong> standards. One commenter suggested HL7 2.5.1 should<br />

be adopted in a future rulemaking. Another commenter suggested that HL7 2.3.1 be<br />

required for the purposes <strong>of</strong> <strong>certification</strong>. Another commenter recommended that the<br />

standard be HL7 2.3.1, because in its opinion many public health agencies cannot comply<br />

with HL7 2.5.1 while another commenter took the opposite position and recommended<br />

HL7 2.5.1.<br />

Response. Given the diversity in implementations and public health agencies’<br />

ability to receive information in a given standard, we believe that the flexibility included<br />

in this criterion is necessary for the foreseeable future. However, relative to the general<br />

comments we received regarding the adoption <strong>of</strong> implementation specifications for<br />

adopted standards, we have adopted the following implementation specifications for HL7<br />

2.5.1: Public <strong>Health</strong> Information Network HL7 Version 2.5 Message Structure<br />

Specification for National Condition Reporting Final Version 1.0 and the Errata and<br />

Clarifications National Notification Message Structural Specification. We believe that<br />

these implementation specifications provide the additional clarity commenters were<br />

Page 97 <strong>of</strong> 228

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