ehr onc final certification - Department of Health Care Services

include in this initial set. Accordingly, we adopted both the CCR and CCD as patient
summary record standards.
We adopted both standards for a few reasons. First, we are aware, contrary to
some commenters’ statements, that a significant segment of the HIT industry still uses the
CCR patient summary record standard and that some health care providers prefer the
CCR over the CCD. For this reason, we did not want to mandate, at such an early stage,
that all of these early adopters adopt a different summary record standard for the purposes
of meaningful use Stage 1, given that electronic health information exchange is not
required. Second, we understand that in some circumstances the CCR is easier, faster,
and requires fewer resources to implement than the CCD. We have therefore concluded
that it was appropriate to adopt the CCR standard for patient summary records in this
initial set of standards. Finally, we believe that at the present time, each standard could
equally be used to satisfy the requirements of meaningful use Stage 1.
Comments. Numerous commenters questioned why we did not adopt the HITSP
C32 implementation specification for the CCD. These commenters requested that we
adopt the C32 implementation specification. They noted that it had been accepted by the
industry, tested and implemented in several operating environments, and was supported
by multiple EHR technology developers. A few commenters requested additional
clarification regarding our adoption of a “level 2” CCD as part of this standard and stated
that use of a level 2 CCD was inconsistent with our adoption of several adopted
vocabulary standards. These commenters questioned whether we intended to adopt a
level 3 CCD. At least one commenter recommended the removal of our reference to
levels. Another commenter stated that problem list, medication list, medication allergy
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