I submitted a Complete EHR for certification, but it has not passed a test for one or more of the certification criteria. Can I request that the ONC-ATCB or ONC-ACB certify the EHR technology that I submitted as an EHR Module instead (i.e., certify only those capabilities that have been tested successfully)?
Yes, an ONC-ATCB or ONC-ACB that is authorized to certify Complete EHRs has the discretion to change the type of certification it would issue based on an EHR technology developer’s request. Whether the ONC-ATCB or ONC-ACB would choose to honor a request for a change, as well as any costs associated with a change, would depend upon the arrangement between the EHR technology developer and the ONC-ATCB or ONC-ACB. Along those lines, if an ONC-ATCB or ONC-ACB permits a developer or presenter to request a different type of certification for the EHR technology it has submitted, the ONC-ATCB or ONC-ACB should be cognizant of other responsibilities it may need to satisfy for EHR Modules (e.g., 45 CFR 170.450 or 170.550).