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ONC Regulation FAQs

#14 Question [09-10-014-2]

I’ve selected a certified Complete EHR [or certified EHR Module] from EHR technology developer XYZ. That being said, I prefer the certified CPOE EHR Module designed by EHR technology developer ABC over the CPOE capability included in EHR technology developer XYZ’s Complete EHR. Can I use the certified CPOE EHR Module from EHR technology developer ABC instead of the CPOE capability included in EHR technology developer XYZ’s certified Complete EHR? Alternatively, can I use both of the certified CPOE capabilities included in EHR technology developer XYZ and ABC’s EHR technologies at the same time? In other words, can I use duplicative or overlapping certified capabilities of different certified EHR technologies without jeopardizing my ability to meaningfully use Certified EHR Technology?

Answer:

Meeting the Certified EHR Technology definition can be achieved in numerous ways, including using EHR technologies that perform duplicative or overlapping capabilities (if that is what an eligible health care provider chooses to do) so long as those EHR technologies are certified. Consequently, an eligible health care provider could use both certified capabilities (e.g., CPOE) at the same time in two different sections/departments of its organization. The eligible health care provider would however be responsible for reconciling the data between those two certified capabilities for purposes of reporting to CMS or the States.

Eligible health care providers who take such an approach should use ONC’s “Certified HIT Products List (CHPL)” webpage to generate a unique certification combination identification in order to accurately attest to CMS or the States the aggregate of certified EHR technologies used during the EHR reporting period.

We also refer readers to the Certified EHR Technology definition at 45 CFR 170.102 and FAQ 17 for further explanation of the Certified EHR Technology definition.

 

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