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ehr onc final certification - Department of Health Care Services

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Comments. Several commenters requested further clarification regarding the<br />

meaning <strong>of</strong> “patient's clinical information.” Other commenters stated that this phrase was<br />

too vague and was not included as part <strong>of</strong> the proposed meaningful use objective or<br />

measure and should therefore be removed. Some commenters requested further<br />

definition <strong>of</strong> the term “specific conditions,” particularly to clarify whether this term refers<br />

to problems and diagnoses. Clarification was also requested regarding whether this<br />

information includes: a patient summary; the patient's entire medical history; and patient<br />

encounter notes. One commenter recommended that we clarify how the lists must be<br />

structured and suggested that we specify time periods for patient histories. One<br />

commenter requested clarification <strong>of</strong> the term “output,” and suggested that it should<br />

mean to produce a list for internal use and that it does not refer to exporting the patient<br />

list to a system or destination external to the <strong>of</strong>fice <strong>of</strong> an eligible pr<strong>of</strong>essional.<br />

Response. We appreciate the c<strong>onc</strong>erns raised by these commenters and after<br />

further consideration agree that the terms referenced by commenters could be interpreted<br />

in multiple ways. Accordingly we have removed “patient’s clinical information” and<br />

“specific conditions” from the <strong>certification</strong> criterion, and have reframed the <strong>certification</strong><br />

criterion to more directly align with the meaningful use measure by changing “output” to<br />

“generate.” We sought to clarify that we intended that Certified EHR technology would<br />

be capable <strong>of</strong> electronically producing or “generating” patient lists for an eligible<br />

pr<strong>of</strong>essional or eligible hospital’s subsequent use. We do not require as a condition <strong>of</strong><br />

<strong>certification</strong> that time periods be associated with a patient list, but presumably time (i.e.,<br />

the age <strong>of</strong> the information) could be one factor an eligible pr<strong>of</strong>essional or eligible hospital<br />

could also use to sort their lists (e.g., patients with XYZ problem recorded in the past 3<br />

Page 76 <strong>of</strong> 228

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