ehr onc final certification - Department of Health Care Services

clarification on why the number of alerts is captured but not what the user did with the
alert and if this data is going to be used to rate providers based upon the number of alerts
they received. Two commenters requested that “responded to by a user” be clarified and
asked whether it meant that a user had taken a different action as a result of the alert.
One commenter recommended removing the alert requirement unless it is more clearly
specified. One commenter recommended deleting the requirement on alert statistics
because it could lead to alert fatigue. A few commenters expressed concern about the
ability to deactivate, modify, and add rules for drug-drug and drug-allergy checking.
These commenters recommended that this capability be removed because of the risk to
patient safety. A commenter noted that treating physicians should have the ability to
ignore alerts in light of other clinical facts about the patient and felt that providing the
ability to delete or modify alerts in a way that would be inconsistent with current medical
standards would be irresponsible and contrary to the meaningful use goal of preserving
the health and safety of patients. Other commenters requested clarification as to whether
the ability to “deactivate” rules implied the ability to remove specific rules or drug pairs
as they exist in commercially‐available clinical decision support (CDS) databases; the
ability to “modify” rules implied that an administrator would be able to change the rules
as they exist in these commercially‐available CDS databases; and the ability to “add” new
rules implied that the administrator could create new rules in commercially‐available
CDS databases. The commenters interpreted “modify” to mean, for example, the ability
to override or change severity setting; and “add” to mean activating a category of CDS,
such as drug‐drug interactions, but not individual rules; and “deactivate” as the ability to
“turn off” specific types of rules. Another commenter requested clarification as to
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