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.

Further, some criteria in the rule represent a step backwards in progress toward EHR interoperability, according to the organization. "For example, well-defined standards for receiving electronic laboratory results in the doctor's office and for exchanging clinical summaries had already been recognized by the federal government and widely supported by industry--as evidenced by the certification of over 80 EHR products to those standards in 2008. Yet under the IFR, that standard for receiving laboratory results and the specific implementation guidance for exchanging clinical data, have been dropped. Where one standard was previously recognized for clinical data exchange, the IFR offers two different, incompatible standards."

The referenced standards are the Continuity of Care Document and the Continuity of Care Record. CCHIT recommends making CCD the required, "or at least clearly preferred," format for certification. "If the above is not possible, clarify the transactions for which each standard applies (e.g., CCD for exchanges between professionals, and CCR for transmission to PHRs and consumer platforms)," according to CCHIT. "This approach would reduce the incidence of lost data structure in provider EHRs where critical clinical decision support takes place."

CCHIT makes more than two-dozen recommendations in its comment letter on the interim final rule. The organization also challenges an economic impact analysis in the rule as an overly simplistic economic model that underestimates the regulatory impact. The letter is available at

--Joseph Goedert

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