ehr onc final certification - Department of Health Care Services

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eceives and have added the term “display” in the beginning of the certification criterion. This change is also applicable to the certification criterion for Complete EHRs and EHR Modules designed for an inpatient setting. Comment. A commenter requested that we clarify how we intended adopted vocabularies to be used. The commenter queried whether vocabulary standards that we had adopted apply to EHRs or to transactions that EHRs conduct. The commenter further requested that we clarify whether a local/proprietary medication vocabulary could be mapped to RxNorm, and whether a local/proprietary problem list vocabulary could be mapped to SNOMED-CT®. Finally, the commenter asked if mapping is permitted, and if so, requested that we identify the subsets of these vocabularies that should be used. Response. For purposes of electronically exchanging a patient summary record, we expect the patient summary record to include health information that is coded, where applicable, in accordance with adopted vocabulary standards. Therefore, unless otherwise required in the context of a meaningful use objective and measure, an eligible professional (or eligible hospital) would be permitted to map or crosswalk local/proprietary codes to the adopted vocabulary standards prior to transmitting a patient summary record. We do not believe that it would be appropriate to specify subsets of adopted vocabularies at this time and would seek additional input from the HIT Standards Committee or public comment prior to specifying vocabulary subsets. Comment. A commenter stated that the adopted data exchange standards do not provide for the inclusion of narrative text results, such as a radiology report, or images of scanned paper documents. The commenter questions how meaningful use objectives will Page 158 of 228
e achieved without these and recommends that implementation guidance be issued that includes specific references to content or vocabulary standards. Response. We have not adopted standards for radiology reports or images; however, both the CCR and CCD can be used to convey narrative text and objects such as scanned documents. Comments. A couple of commenters requested clarification as to the testing we expected to occur related to a Complete EHR or EHR Module’s compliance with this certification criterion. These commenters questioned whether the generation of a CCD and XDS (HITSP/TP13)/FTP/email of a document would meet the certification criterion requirements. Response. We clarify that because we have removed the adopted transport standards, we do not require as a condition of certification that a specific transport standard be used to transmit a generated CCD. Comments. One commenter expressly agreed with the expectations of the certification criterion. Another commenter stated that this functionality is crucial to support the patient/family-centered medical home. One commenter recommended that the Certified EHR Technology be designed so that the amount of data transmitted could be adjusted by physicians so they do not violate the HIPAA Privacy Rule’s “minimum necessary” requirements. Response. We appreciate commenters’ support for this certification criterion and agree that patient summary records serve a valuable purpose. Presently, we do not believe that it is appropriate to require as a condition of certification a capability associated with the HIPAA Privacy Rule’s minimum necessary requirements because Page 159 of 228
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DEPARTMENT OF HEALTH AND HUMAN SERV
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HHS Department of Health and Human
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5. Definition of Qualified EHR 6. D
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technology. Section 3004(b)(1) of t
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esolve identified technical challen
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Some commenters appear to have misi
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efficiencies and desired quality im
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codes must be used “inside” an
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not necessarily have applied to our
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3. Definition of Implementation Spe
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program established by the National
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criteria adopted by the Secretary a
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Comment. In the context of the defi
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y the certification criteria for a
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commenters asked whether we meant t
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adopted by the Secretary. The secon
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Response. We would like to make cle
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Response. In the Interim Final Rule
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could be a health care professional
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standard for certain purposes. In s
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e voluntary and would not be requir
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already existing regulatory require
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setting). We also include, where ap
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clarification on why the number of
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more clearly specify this capabilit
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Response. While we do not require t
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that check, the functionality show
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Response. The comments are correct
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enable the user to electronically r
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longitudinal care, or whether the E
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EHR and EHR Module developers to pr
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suggestions for different age range
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Record smoking status for patients
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23) during the EHR reporting period
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laboratory test results are receive
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commenters reasoned that because a
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laboratory test results to be elect
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or outreach Generate patient lists.
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months). We believe that these revi
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that the PQRI 2009 Registry XML spe
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To better align this certification
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the capability specified by the cer
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vendors were unwilling or unable to
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the concerns expressed by some comm
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Page 89 of 228 electronically compa
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(1) The standard (and applicable im
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for the purposes of demonstrating c
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Guide for Immunization Messaging Re
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Response. We clarify for commenters
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serve as a limiting factor, however
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Page 101 of 228 Unchanged Comment.
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Comment. One commenter suggested th
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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
Page 145 and 146: in accordance with one of the adopt
Page 147 and 148: Comments. Many commenters suggested
Page 149 and 150: flexibility in this certification c
Page 151 and 152: productive, confusing, time-consumi
Page 153 and 154: include in this initial set. Accord
Page 155 and 156: to the HITSP C32 implementation spe
Page 157: Response. Again, we do not believe
Page 161 and 162: electronically record, store, retri
Page 163 and 164: EHRs and EHR Modules designed for a
Page 165 and 166: §170.205(a)(2)(iii); and (v) The s
Page 167 and 168: Response. We disagree, as doing so
Page 169 and 170: Dental Terminology as a condition o
Page 171 and 172: However, we do not preclude Complet
Page 173 and 174: ability of CCD and CCR to support t
Page 175 and 176: ability to receive these reports. M
Page 177 and 178: commenters acknowledged and express
Page 179 and 180: a meaningful use objective they wou
Page 181 and 182: CMS and ONC had worked together to
Page 183 and 184: The eligible professional or eligib
Page 185 and 186: EHR technology with the needs of us
Page 187 and 188: The RFA requires agencies to analyz
Page 189 and 190: values seemed low and that the gap
Page 191 and 192: commenter provided), our assumption
Page 193 and 194: absolute low we estimated for a per
Page 195 and 196: number of previously CCHIT-certifie
Page 197 and 198: for Certification Low High Page 197
Page 199 and 200: Finally, the third type of cost we
Page 201 and 202: 2012 15% $10.10 $30.80 $20.45 3-Yea
Page 203 and 204: The RFA requires agencies to analyz
Page 205 and 206: The Office of Management and Budget
Page 207 and 208: The standards and implementation sp
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The Secretary adopts the following
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any edition other than that specifi
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(e) Regenstrief Institute, Inc., LO
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4. Revise subpart C to read as foll
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smoker; current some day smoker; fo
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(2) Generate audit log. Enable a us
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(3) Medication allergy list; (4) De
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§170.205(a)(1) or §170.205(a)(2).
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(d) Electronic copy of health infor
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specifications) specified in §170.
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