#33 Question [12-12-033-1]

Certain data found in paragraphs 45 CFR 170.314 (e)(2)(iii)(A) and (B), appear duplicative in the listing of the required data for the EHR technology clinical summary certification criterion. For that data and also for “immunizations” as part of the clinical summary certification criterion, how will these be tested and certified where vocabulary standards have been adopted?


In subparagraphs 45 CFR 170.314 (e)(2)(iii)(A) and (B), we list the minimum data EHR technology must permit a user to select when creating a clinical summary. However, upon further analysis, we have identified inadvertent redundancies between subparagraphs (A) and (B) that we now seek to clarify. As identified in the table below, certain data specified in subparagraph (B)are duplicative or are generally redundant of those listed in subparagraph (A) as part of the Common MU Data Set. For those data where duplication exists, we have clarified whether testing and certification will require an adopted vocabulary standard. For testing and certification of “immunizations” in clinical summary data, we also provide such clarification:

Data specified in subparagraph (B)

Specified in subparagraph (A) as part of the Common MU Data Set?

Will testing and certification require the use of the adopted vocabulary standard?

Medications Yes, as Medications Yes; RxNorm.
“Diagnostic tests pending” and “Future scheduled tests” Yes, as Lab Tests Yes; to the degree that such “tests” could be coded in LOINC.
Immunizations No No; however, we encourage EHR technology developers to use the CVX code set similar to how it is required in other adopted


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Content last reviewed on April 11, 2019
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