The certification criterion at 45 CFR 170.302(n) specifies (and similarly specified in 45 CFR 170.314(g)(2)) that “[f]or each meaningful use objective with a percentage-based measure, electronically record the numerator and denominator and generate a report including the numerator, denominator, and resulting percentage associated with each applicable meaningful use measure.” Is it possible for the action of “record” in the certification criterion to be implemented in different ways and still remain in compliance with the certification criterion? For example, could “record” comprise the ability of a centralized analytics EHR Module to accept or retrieve raw data from another EHR Module or EHR Modules, and upon receipt of this raw data, the centralized analytics EHR Module would calculate the numerator, denominator, and the resulting percentage as specified by 45 CFR 170.302(n) and 170.314(g)(2)?
Answer:
Yes, it is possible for the action of “record” in this certification criterion to be implemented in different ways. The example in this question appears to be one possible way to demonstrate compliance with this certification criterion. Other possible methods could include a Complete EHR that accepts or retrieves raw data, analyzes the data, and then generates a report based on the analysis; a Complete EHR that separately tracks each capability with a percentage-based meaningful use measure and later aggregates the numbers and generates a report; or an integrated bundle of EHR Modules in which each of the EHR Modules that is part of the bundle categorizes relevant data, identifies the numerator and denominator and calculates, when requested, the percentage associated with the applicable meaningful use measure. In each of these examples, the action of “record” means to obtain the information necessary to generate the relevant numerator and denominator.