ehr onc final certification - Department of Health Care Services

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Again, using our general assumptions discussed above (40 certification criteria and a low and high range of $10,000 to $250,000 per certification criterion) we have made the following additional assumptions in our Table 2 calculations based on our understanding of the capabilities currently present in these EHR technologies: 1) in general, Complete EHR developers who have out-of-date CCHIT-Certified-EHRs or who never previously had their Complete EHRs certified by CCHIT will possess Complete EHRs that will meet approximately 40% of the adopted certification criteria and, as a result, these Complete EHR developers may need to make more comprehensive adjustments to their Complete EHRs in order to prepare the Complete EHRs to be tested and certified to the remaining 60% of the certification criteria adopted by the Secretary; 2) the average low and high per certification criterion costs for Complete EHRs for eligible professionals to be prepared to be tested and certified will be $50,000 and $150,000, respectively; and 3) the average low and high per certification criterion costs for Complete EHRs for eligible hospitals to be prepared to be tested and certified will be $75,000 and $200,000, respectively. Table 2. Estimated One-Time Costs for Complete EHR Developers to Prepare Never CCHIT- Certified-EHRs and Out-of-Date CCHIT-Certified-EHRs to be Tested and Certified (3 year period) – Totals Rounded One Time Cost Per Total Cost for All EHRs over 3-year Number EHR ($M) Period ($M) Prepared for Mid- Type Complete EHRs for Eligible Certification Low High point Low High Mid-point Professionals Complete EHRs for Eligible 8 $1.2 $3.6 $2.4 $9.6 $28.8 $19.2 Hospitals 5 $1.8 $4.8 $3.3 $9.0 $24.0 $16.5 Total 13 $18.60 $52.80 $35.70 Page 198 of 228
Finally, the third type of cost we estimate relates to the number of EHR Modules we expect to be prepared to be tested and certified and the costs associated with that preparation. We clarify as noted in the Temporary Certification Program final rule that these EHR Modules are not “self-developed,” and we assume that an EHR Module developer interested in commercially marketing its EHR Module to eligible professionals and eligible hospitals would develop them. We assumed in the Interim Final Rule that certain types of EHR Modules (e.g., computerized provider order entry; quality reporting; online patient portals) would be more likely than others to be prepared to be tested and certified, and we estimated based on our assumption that there would be 7 EHR Modules prepared to be tested and certified for each of the 7 types of EHR Modules we identified. This estimate (number of modules X types of modules) resulted in an approximate number of 50 EHR Modules that would be prepared to be tested and certified. Again, we have provided low and high preparation cost estimates in Table 3 below. We assume that some of EHR Modules prepared for certification will be capable of meeting applicable certification criteria with little modification while other EHR Modules will not. Given the potential differences in preparation costs and combinations of certification criteria to create EHR Modules, we believe it is reasonable to estimate a wide range of costs for preparing these types of EHR Modules for testing and certification. We estimated in the Interim Final Rule and reiterate below a low average one-time cost of $100,000 to prepare an EHR Module, based on the assumption that some of the less sophisticated EHR Modules would only be prepared to be tested and certified to 1 or 2 certification criteria. We estimated in the Interim Final Rule and reiterate below, a high average cost one-time cost of $500,000 to prepare an EHR Module, based on the assumption that some Page 199 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
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Complete EHRs or EHR Modules design
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Response. We disagree. As stated ab
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Response. As discussed above, we ha
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SHA-1 and other secure hash algorit
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misinterpreted our example and stat
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Other commenters also expressed con
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eferenced in FIPS 140-2 Annex A, wh
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of the most secure encryption algor
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the disclosure was made (recipient)
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Use CPOE for medication orders dire
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equire EHRs to build custom interfa
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esult, we do not believe that this
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was needed before RxNorm could be a
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• MDDB - Medi-Span Master Drug Da
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Response. We do not believe that it
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Send reminders to patients per pati
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specified data elements and CMS’s
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what would qualify as a "response."
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Comment. A commenter recommended th
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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 and 158: Response. Again, we do not believe
Page 159 and 160: e achieved without these and recomm
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
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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
Page 209 and 210: The Secretary adopts the following
Page 211 and 212: any edition other than that specifi
Page 213 and 214: (e) Regenstrief Institute, Inc., LO
Page 215 and 216: 4. Revise subpart C to read as foll
Page 217 and 218: smoker; current some day smoker; fo
Page 219 and 220: (2) Generate audit log. Enable a us
Page 221 and 222: (3) Medication allergy list; (4) De
Page 223 and 224: §170.205(a)(1) or §170.205(a)(2).
Page 225 and 226: (d) Electronic copy of health infor
Page 227 and 228: specifications) specified in §170.
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