The Certification Commission for Health Information Technology, in a letter commenting on the interim final rule establishing an initial set of data standards, implementation specifications and electronic health records certification criteria, calls for slightly reducing the scope of functionality a "Complete EHR" should have.

Including two functions of an administrative/billing system in the scope of EHR certification "may exclude one third or more of the offerings in the current EHR marketplace, while suddenly forcing hundreds of billing products to undergo unnecessary certifications," CCHIT contends in its letter.

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