ehr onc final certification - Department of Health Care Services
ehr onc final certification - Department of Health Care Services
ehr onc final certification - Department of Health Care Services
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eason we have permitted either to be used for purposes <strong>of</strong> <strong>certification</strong>. We also<br />
understand that eligible pr<strong>of</strong>essionals and eligible hospitals will have to use the standard<br />
that the immunization registry or Immunization Information System in their jurisdiction<br />
can receive and, as a result, we have adopted the two most common standards utilized for<br />
the transmission <strong>of</strong> immunization information.<br />
Comment. One commenter noted that it would be very helpful to provide a<br />
source for mapping from the NDC code on the vaccine packaging to the CVX/MVX<br />
codes used for interoperability, in anticipation <strong>of</strong> supporting barcode scanning <strong>of</strong><br />
vaccines. Another commenter noted that while some mapping has occurred between<br />
CPT and CVX, they were not aware <strong>of</strong> a translation map from NDC to CVX. They also<br />
stated that even though a list <strong>of</strong> CVX codes is available, they were not aware <strong>of</strong> a<br />
downloadable immunization database using CVX codes. They considered this lack <strong>of</strong> a<br />
database a significant burden and impediment to compliance. The commenter c<strong>onc</strong>luded<br />
by suggesting that CPT codes be used instead <strong>of</strong> CVX codes, because CPT codes are<br />
used for billing purposes and would be readily available.<br />
Response. The CDC maintains an openly available list <strong>of</strong> updated CVX codes as<br />
well as a mapping <strong>of</strong> CVX codes to CPT codes on their website. 4 Moreover, we believe<br />
that CVX codes are more appropriate than CPT codes because as the commenter<br />
referenced, CPT codes are used for billing purposes. In that regard, we believe that<br />
because there is a publicly available mapping between CVX and CPT, it would not be<br />
difficult or burdensome to map CPT codes to CVX codes. NDC codes were not adopted<br />
as a standard to represent immunizations and we do not believe that requiring their use<br />
4 www.cdc.gov/vaccines/programs/iis/stds/cpt.htm<br />
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