ehr onc final certification - Department of Health Care Services

longitudinal care, or whether the EHR Module could be designed to provide those
capabilities through its interaction with a device or devices at the enterprise level).
Comment. One comment stated that this criterion should include a provision to
include the ability to transmit this information to public health entities as required by law.
Response. Nothing we adopt in this final rule precludes such a capability from
being included in a Complete EHR or EHR Module. That is not, however, currently a
necessary requirement for certification.
Comments. One commenter stated that it would need to perform extensive
reprogramming to accommodate the standard we adopted if it meant modifying
underlying medication databases. This commenter suggested that this standard as it
applied to the maintenance of medication lists be deferred. Along those lines, a couple of
commenters stated that more clarification was needed with respect to whether RxNorm
identifiers needed to be stored internally within Certified EHR Technology or only
needed to be used upon the electronic exchange of health information. Other commenters
expressly stated that the mapping of the vocabulary be limited to instances where the
electronic exchange of health information would take place.
Response. We understand these commenters’ concerns and agree that it would be
premature to require the use of the adopted standard in this context. In that regard, we
seek to clarify for commenters our intention, which was solely to associate this adopted
standard (as some commenters suggested) with the certification criteria that require the
capability to electronically exchange health information. We recognize that continuing to
associate this standard with the adopted certification criterion could potentially impose a
significant burden on the industry, which we did not intend. Accordingly, we have
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