#25 Question [06-12-025-2]
For an eligible professional using EHR technology certified to the 2011 Edition, can the definition of Certified EHR Technology be met by combining EHR technology certified for an inpatient setting with EHR technology certified for an ambulatory setting?
Yes. For all of the certification criteria that apply to Complete EHRs or EHR Modules designed for use in an ambulatory setting for which there is an equivalent or more comprehensive certification criterion that applies to Complete EHRs or EHR Modules designed for use in an inpatient setting, the EP may include the EHR technology tested and certified to the inpatient certification criteria as part of the EHR technology the EP possesses. For example, the “electronic copy of the health information” certification criterion adopted for the inpatient setting at 45 CFR 170.306(d) is more comprehensive (i.e., requires more data but not less) than the certification criterion adopted at 45 CFR 170.304(f) for the ambulatory setting. As discussed in the Standards and Certification Criteria interim final rule and the July 2010 final rule, we believe that the clinical setting should determine the applicable certification criteria. The following five certification criteria fall within this flexibility:
- 170.304(a) which is the same as 170.306(a);
- 170.304(e) which is the same as 170.306(c);
- 170.306(b) which is more comprehensive than 170.304(c);
- 170.306(d) which is more comprehensive than 170.304(f); and
- 170.306(f) which is more comprehensive than 170.304(i).
However, in order for an EP to possess EHR technology that meets the definition of Certified EHR Technology, the EP will also need to possess EHR technology with capabilities that are unique to the ambulatory setting and for which certification is required (e.g., electronic prescribing (170.304(b)); patient reminders (170.304(d); timely access; (170.304(g)); clinical summaries (170.304(h)); clinical quality measures (170.304(j))).
EPs that pursue this approach should use ONC’s “Certified HIT Products List (CHPL)” webpage to generate a “CMS EHR ID #” to accurately attest to CMS or States the combination of certified EHR technologies used during the EHR reporting period. Further instruction on this approach is provided on the CHPL.