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The following are more detailed explanations of each permitted approach.  We also emphasize that regardless of the way an EP, eligible hospital, or CAH chooses to transmit the summary of care record, such a transmission will only count in the numerator if it is received by the provider to whom the sending provider is referring or transferring the patient.

1. Use of the transport standard capability required for certification.  As required by ONC to meet the CEHRT definition, every EP, eligible hospital, and CAH, must have EHR technology that is capable of electronically transmitting a summary care record for transitions of care and referrals according to the primary Direct Project specification (the Applicability Statement for Secure Health Transport).  Thus, EPs, eligible hospitals, or CAHs that electronically transmit summary care records using their CEHRT’s “Direct” capability (natively or combined with an intermediary) would be able to count all such electronic transmissions in their numerator.

2. Use of the SOAP-based optional transport standard capability permitted for certification.  As part of certification, ONC permits EHR technology developers to voluntarily seek certification for their EHR technology’s capability to perform SOAP-based electronic transmissions.  EHR technology developers who take this approach would enable their customers to also use this approach to meet the measure.  Thus, EPs, eligible hospitals, or CAHs that electronically transmit summary care records using their CEHRT’s “SOAP-based” capability (natively or combined with an intermediary) would be able to count all of those transmissions in their numerator.

3. Use of CEHRT to create a summary care record in accordance with the required standard (i.e., Consolidated CDA as specified in 45 CFR 170.314(b)(2)), and the electronic transmission is accomplished through the use of an eHealth Exchange participant who enables the electronic transmission of the summary care record to its intended recipient.  Thus, EPs, eligible hospitals, or CAHs who create standardized summary care records using their CEHRT and then use an eHealth Exchange participant to electronically transmit the summary care record would be able to count all of those transmissions in their numerator. 

We note that for this third approach, the regulation also permits an EP, eligible hospital, or CAH to count in their numerator instances where a summary care record for transitions of care or referrals was received via electronic exchange facilitated in a manner consistent with the governance mechanism ONC establishes for the nationwide health information network.  ONC has not yet established a governance mechanism for the nationwide health information network.  Until ONC establishes such a governance mechanism, this specific option will not be available.

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