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ehr onc final certification - Department of Health Care Services

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Along these same lines, another commenter recommended that EHR technology should<br />

be tested and certified only to the clinical quality measures applicable to the medical<br />

specialties <strong>of</strong> the eligible pr<strong>of</strong>essionals that the EHR technology is intended to support<br />

and to whom it is marketed. Other commenters expressed c<strong>onc</strong>erns about timing and that<br />

a significant amount <strong>of</strong> effort would be required to reprogram Complete EHRs and EHR<br />

Modules to capture, calculate, and report the <strong>final</strong> meaningful use Stage 1 measures.<br />

Many commenters also stated that the proposed quality measures are not yet ready for<br />

automated reporting, that a significant amount <strong>of</strong> work is still required by the measure<br />

developer community, and that the value sets for these quality measures have not been<br />

validated. Several commenters objected to the reference to “States” in the <strong>certification</strong><br />

criterion and recommended that it be removed. These commenters contended that the<br />

<strong>certification</strong> criterion should be limited to the “federal requirements” and further that it<br />

was unrealistic to expect Complete EHR and EHR Module developers to also comply<br />

with 50 separate State requirements as a condition <strong>of</strong> <strong>certification</strong>.<br />

Response. We understand that CMS has worked to significantly increase the<br />

availability <strong>of</strong> a number <strong>of</strong> electronic measure specifications that are associated with<br />

specific clinical quality measures. In light <strong>of</strong> the <strong>final</strong> approach CMS has taken with<br />

respect to clinical quality measures for meaningful use Stage 1, we have revised this<br />

<strong>certification</strong> to better align it with the Medicare and Medicaid EHR Incentive Programs<br />

<strong>final</strong> rule requirements. We also agree with those commenters that requested we<br />

explicitly focus the report <strong>of</strong> clinical quality measures <strong>certification</strong> criterion, and the<br />

<strong>certification</strong> criteria in general, on Federal requirements and have removed the reference<br />

to “or States” in this <strong>certification</strong> criterion.<br />

Page 80 <strong>of</strong> 228

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