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ehr onc final certification - Department of Health Care Services

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Comments. A few commenters asked for clarification as to whether SNOMED-<br />

CT® or ICD-9CM codes needed to be included within Certified EHR Technology or if<br />

these standards were only necessary when electronic health information is exchanged.<br />

Some <strong>of</strong> these commenters also requested that we permit any coding system to be used as<br />

long as it can be mapped to the appropriate format when electronic health information is<br />

to be exchanged.<br />

Response. As previously discussed, meaningful use requirements will typically<br />

specify whether an adopted standard will have to be used among components <strong>of</strong> a<br />

business organization or solely for the electronic exchange <strong>of</strong> health information with<br />

other legal entities. The measure for this <strong>final</strong> meaningful use objective provides that<br />

entries be recorded as structured data. The <strong>certification</strong> criterion specifies that ICD-9CM<br />

or SNOMED-CT® are the code sets which must be included in Certified EHR<br />

Technology, and are therefore the code sets that would be used to record entries as<br />

structured data.<br />

Comments. A few commenters recommended the removal <strong>of</strong> “longitudinal care”<br />

in the <strong>certification</strong> criterion. These commenters cited our clarification in the preamble<br />

that by longitudinal care we meant “over multiple <strong>of</strong>fice visits.” These commenters<br />

questioned how this language would be applicable to an inpatient setting since patients<br />

are typically treated for acute episodes and not over multiple <strong>of</strong>fice visits.<br />

Response. The reference to longitudinal care is intended to convey that the<br />

problem list must be comprehensive in the sense that it must be capable <strong>of</strong> including<br />

entries provided over an extended period <strong>of</strong> time. Consequently, for Complete EHRs and<br />

EHR Modules to be certified for an ambulatory setting, they will need to be designed to<br />

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