Do the 2011 Edition and 2014 Edition certification criteria pertaining to electronic prescribing, which reference certain content exchange standards (e.g., NCPDP SCRIPT 10.6), require that a Complete EHR or EHR Module be capable of electronically exchanging information with only external recipients (i.e., recipients that are not part of that legal entity) according to the appropriate standard (and implementation specifications) or do they apply more broadly?
The 2011 Edition and 2014 Edition certification criteria pertaining to electronic prescribing refer to the capability of electronically exchanging information only with external recipients. The certification criteria adopted at (45 CFR 170.304(b) and 170.314(b)(3)) for electronic prescribing reference content exchange and vocabulary standards that were adopted for the purpose of enabling a user of Certified EHR Technology to electronically “exchange” certain health information with different legal entities. As we explained in the proposed and final rules for the 2014 Edition EHR certification criteria (77 FR 13845 and 77 FR 54198), this position is consistent with and supports the meaningful use policy for the electronic prescribing MU objective as described in the Stage 2 proposed and final rules (77 FR 13710 and 77 FR 53989).