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ehr onc final certification - Department of Health Care Services

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what would qualify as a "response." One commenter stated that whether we intended for<br />

the examples (pop-up or sound) to be inclusive <strong>of</strong> the types <strong>of</strong> alerts we expected<br />

Certified EHR Technology would include and whether this was deemed more valuable<br />

than a more passive notification. The commenter suggested that the word “alert” be<br />

replaced with “notification” while another suggested the word “advisory.” Some<br />

commenters requested clarification regarding “alerts responded to by a user” and whether<br />

there was an expectation that alerts communicate structured reasons. These commenters<br />

also asked whether users would enter a reason for any overrides or, in the case <strong>of</strong><br />

notifications, the user would simply acknowledge the alert by clicking “OK.” The<br />

commenters also questioned whether ignored alerts should be tracked? Many <strong>of</strong> these<br />

commenters recommended removing §170.304(e)(3). Alternatively, one commenter<br />

recommended that we not only consider the number <strong>of</strong> alerts “responded to” but also the<br />

action prompted and whether or not that action was taken.<br />

Response. We thank commenters for the thorough feedback on this <strong>certification</strong><br />

criterion. We have already addressed in our responses above the c<strong>onc</strong>erns raised by<br />

commenters and will not repeat them here. With respect to the third part <strong>of</strong> this<br />

<strong>certification</strong> criterion, we have considered public comment and have decided to remove<br />

the requirement from the <strong>certification</strong> criterion. We also removed this requirement to be<br />

more consistent with CMS’s expectations for meaningful use, which do not include<br />

requiring the tracking <strong>of</strong> alerts at this time.<br />

Comments. A few commenters asked for clarification on what we meant by<br />

"evidence grade" and what standard for evidence grading will be applied in order to<br />

determine compliance with this objective. Other commenters noted that “evidence<br />

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