ehr onc final certification - Department of Health Care Services

As we noted in the Interim Final Rule, we analyzed previously developed CCHIT
ambulatory and inpatient certification criteria and believe that many of those criteria, but
not all, require the exact same capabilities as the certification criteria adopted by the
Secretary at 45 CFR 170.302, 45 CFR 170.304, and 45 CFR 170.306. Generally
speaking, we believe this overlap includes most of the clinically oriented capabilities
required by the certification criteria adopted by the Secretary. Accordingly, we believe
that a significant number of previously CCHIT-certified-EHRs will only incur moderate
costs to prepare for certification. For the purpose of estimating costs, we presume that
previously CCHIT-certified-EHRs include the functionality to meet the definition of a
Complete EHR. As a result, for our estimates in Table 1, we anticipate that these
previously CCHIT-certified-EHRs will again be prepared for certification as Complete
EHRs. We estimated in the Interim Final Rule that there were 74 CCHIT-certified-EHRs
certified to its 2008 ambulatory certification criteria and 17 CCHIT-certified-EHRs
certified to its 2007 or 2008 inpatient certification criteria. 11,12,13 Of these 74 and 17
previously CCHIT-certified-EHRs, we expect that 90% will be prepared and submitted
for certification according to the certification criteria adopted by the Secretary. We do
not believe that it is realistic to assume that 100% of previously CCHIT-certified-EHRs
will be prepared for certification for a number of reasons. These reasons include: 1) a
recognition that mergers and acquisitions within the marketplace have reduced the
11 Some are marked with a conditional certification either “Pre-Market: These are conditionally certified
EHRs which are new products that are fully certified once their operational use at a physician office site
has been verified.” or “eRx Conditional: These are conditionally certified pending advanced ePrescribing
EHRs that are in the process of verifying their ability to conduct medication history, formulary and
eligibility checking through a national network for electronic-prescribing transactions.” We do not believe
that these caveats have any discernible effect on our estimates.
12 http://www.cchit.org/products/Ambulatory -- when certification years 2006 and 2007 are unchecked.
While 78 EHRs are now listed, we do not believe that changing our estimate would have a measureable
effect on the overall costs.
13 http://www.cchit.org/products/Inpatient
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