The “electronic copy of health information” certification criteria (45 CFR 170.304(f) and 45 CFR 170.306(d)) each require that Certified EHR Technology “enable a user to create an electronic copy of a patient’s clinical information… in: (1) Human readable format; and (2) On electronic media or through some other electronic means….” Is there more than one way to demonstrate compliance with these certification criteria?
Yes, as discussed in the Initial Set of Standards, Implementation Specifications, and Certification Criteria Final Rule published in July 2010 (75 FR 44630), there is more than one way to demonstrate compliance with these certification criteria. For these certification criteria, Certified EHR Technology must be capable of generating two outputs to produce an electronic copy (i.e., a copy in human readable format and a copy as a CCD or CCR). If the Certified EHR Technology is capable of generating one copy that could meet both of these requirements, we would also consider that to be a compliant implementation of this capability.
Note: This answer is only relevant to 2011 Edition EHR certification as the “electronic copy of health information” certification criteria were revised and merged into the “view, download, and transmit to a 3rd party” certification criterion as part of the 2014 Edition EHR certification criteria.