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ONC Regulation FAQs

#18 Question [09-10-018-2]

I use or would like to use an “interface” to submit data to a public health agency/registry. Does this interface need to be certified?

Answer:

It depends. We recognize that the term “interface” has several different meanings depending on the context in which it is used, the IT infrastructure of which it is a part, and the capability it performs. Consequently, depending on various factors, an interface may or may not need to be certified.

“NO”

  • The answer to your question would be “no,” if the interface provided a user with the ability to directly enter data to the public health agency/registry. In that scenario, the interface would not be providing a capability for which the Secretary has adopted a certification criterion and that Certified EHR Technology must include.
  • Similarly, if the interface would solely be serving as a conduit between your EHR technology and the public health agency/registry and providing the underlying communication protocol to transport data from point A to point B, it would not need to be certified. In this case, the interface would simply be providing the connection between you and the public health agency/registry and the means for the submission to occur. The interface would not be providing the capability specified in the certification criterion adopted by Secretary, which Certified EHR Technology must include.

“YES” 

  • If, however, the interface were to perform a capability specified in an adopted certification criterion and the interface was intended to satisfy a correlated meaningful use requirement, it would need to be certified. Why? Because you are required to use Certified EHR Technology to demonstrate meaningful use and qualify for your respective EHR incentive program. As an example, if the interface was intended to provide the capability of electronically recording, modifying, retrieving and submitting immunization information according to the standards required by 45 CFR 170.302(k) or the capability to create immunization information for transmission according to the standards required by 45 CFR 170.314(f)(2), it would need to be certified.

 

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