ehr onc final certification - Department of Health Care Services

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Comment. A commenter recommended that “drug-test checks” should be added. The commenter stated that many drugs require some form of laboratory testing to ensure that drugs are prescribed appropriately. The commenter stated, for example, that an anticoagulant medication should not be prescribed unless there is a test result on record that shows that giving this drug would not cause harm. Response. Presently, drug-test checking is not a required capability for eligible professionals and eligible hospitals to use in order to successfully meet the requirements of meaningful use Stage 1. Accordingly, we do not believe that it would be appropriate to require Certified EHR Technology to be capable of performing drug-test checks as a condition of certification at the present time. §170.302(b) - Maintain up-to-date problem list Meaningful Use Stage 1 Objective Maintain an up-todate problem list of current and active diagnoses Meaningful Use Stage 1 Measure More than 80% of all unique patients seen by the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) have at least one entry or an indication that no problems are known for the patient recorded as structured data Page 54 of 228 Certification Criterion Interim Final Rule Text: Maintain up-to-date problem list. Enable a user to electronically record, modify, and retrieve a patient’s problem list for longitudinal care in accordance with: (1) The standard specified in §170.205(a)(2)(i)(A); or (2) At a minimum, the version of the standard specified in §170.205(a)(2)(i)(B). Final Rule Text: §170.302(c) Final rule text remains the same as Interim Final Rule text, except for references to adopted standards, which have been changed. Comments. Several commenters expressed concerns about the use of ICD-9-CM because it is primarily used for billing and administrative purposes and may not accurately represent the true clinical meaning of a problem or condition when it is documented at the point of care. One commenter stated a concern that the problem list standards do not allow for capturing of free text that health care providers use when an appropriate code is in neither SNOMED-CT® nor ICD-9-CM.
Response. The comments are correct in that ICD-9-CM is primarily used for billing and administrative purposes. SNOMED-CT® is offered as an alternative standard that will support more clinical descriptions of patient problems or conditions. We believe that with the adoption of both SNOMED-CT® and ICD-9-CM, healthcare providers should have adequate coverage for patient diagnoses and conditions. We are discouraging the use of free text for documenting problem lists since this will limit the usefulness of problem lists for clinical reminders, decision support and other patient safety and quality reporting. Comments. Several commenters recommended that only SNOMED-CT® be adopted, or alternatively, that we expressly indicate an intention to move away from ICD- 9CM and ICD-10 in the future. Another commenter recommended against the adoption of SNOMED-CT® because the commenter felt that our adoption of SNOMED-CT® would require eligible professionals and eligible hospitals to use both ICD-9-CM and SNOMED-CT®. One commenter recommended that a publicly vetted and HHS approved standard mapping between ICD-9-CM and SNOMED CT® should be made available at the public’s expense. Response. We agree conceptually that a single standard for clinical information would be desirable in the long term. However, presently both ICD-9-CM and SNOMED- CT® are used by EHR technology to code clinical information, and adopting both would provide users with additional flexibility. Moreover, we anticipate that as meaningful use objectives and measures evolve over time, we will receive additional public input and experience related to these standards and may eventually be able to adopt only one standard. Page 55 of 228
Page 1 and 2:
DEPARTMENT OF HEALTH AND HUMAN SERV
Page 3 and 4: HHS Department of Health and Human
Page 5 and 6: 5. Definition of Qualified EHR 6. D
Page 7 and 8: technology. Section 3004(b)(1) of t
Page 9 and 10: esolve identified technical challen
Page 11 and 12: Some commenters appear to have misi
Page 13 and 14: efficiencies and desired quality im
Page 15 and 16: codes must be used “inside” an
Page 17 and 18: not necessarily have applied to our
Page 19 and 20: 3. Definition of Implementation Spe
Page 21 and 22: program established by the National
Page 23 and 24: criteria adopted by the Secretary a
Page 25 and 26: Comment. In the context of the defi
Page 27 and 28: y the certification criteria for a
Page 29 and 30: commenters asked whether we meant t
Page 31 and 32: adopted by the Secretary. The secon
Page 33 and 34: Response. We would like to make cle
Page 35 and 36: Response. In the Interim Final Rule
Page 37 and 38: could be a health care professional
Page 39 and 40: standard for certain purposes. In s
Page 41 and 42: e voluntary and would not be requir
Page 43 and 44: already existing regulatory require
Page 45 and 46: setting). We also include, where ap
Page 47 and 48: clarification on why the number of
Page 49 and 50: more clearly specify this capabilit
Page 51 and 52: Response. While we do not require t
Page 53: that check, the functionality show
Page 57 and 58: enable the user to electronically r
Page 59 and 60: longitudinal care, or whether the E
Page 61 and 62: EHR and EHR Module developers to pr
Page 63 and 64: suggestions for different age range
Page 65 and 66: Record smoking status for patients
Page 67 and 68: 23) during the EHR reporting period
Page 69 and 70: laboratory test results are receive
Page 71 and 72: commenters reasoned that because a
Page 73 and 74: laboratory test results to be elect
Page 75 and 76: or outreach Generate patient lists.
Page 77 and 78: months). We believe that these revi
Page 79 and 80: that the PQRI 2009 Registry XML spe
Page 81 and 82: To better align this certification
Page 83 and 84: the capability specified by the cer
Page 85 and 86: vendors were unwilling or unable to
Page 87 and 88: the concerns expressed by some comm
Page 89 and 90: Page 89 of 228 electronically compa
Page 91 and 92: (1) The standard (and applicable im
Page 93 and 94: for the purposes of demonstrating c
Page 95 and 96: Guide for Immunization Messaging Re
Page 97 and 98: Response. We clarify for commenters
Page 99 and 100: serve as a limiting factor, however
Page 101 and 102: Page 101 of 228 Unchanged Comment.
Page 103 and 104: Comment. One commenter suggested th
Page 105 and 106:
Response. We appreciate the thought
Page 107 and 108:
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
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Comments. Many commenters suggested
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flexibility in this certification c
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productive, confusing, time-consumi
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include in this initial set. Accord
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to the HITSP C32 implementation spe
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Response. Again, we do not believe
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e achieved without these and recomm
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electronically record, store, retri
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EHRs and EHR Modules designed for a
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§170.205(a)(2)(iii); and (v) The s
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Response. We disagree, as doing so
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Dental Terminology as a condition o
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However, we do not preclude Complet
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ability of CCD and CCR to support t
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ability to receive these reports. M
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commenters acknowledged and express
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a meaningful use objective they wou
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CMS and ONC had worked together to
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The eligible professional or eligib
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EHR technology with the needs of us
Page 187 and 188:
The RFA requires agencies to analyz
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values seemed low and that the gap
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commenter provided), our assumption
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absolute low we estimated for a per
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number of previously CCHIT-certifie
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for Certification Low High Page 197
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Finally, the third type of cost we
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2012 15% $10.10 $30.80 $20.45 3-Yea
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The RFA requires agencies to analyz
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The Office of Management and Budget
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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).
Page 225 and 226:
(d) Electronic copy of health infor
Page 227 and 228:
specifications) specified in §170.
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ehr onc final certification - Department of Health Care Services

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