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  2. CQM-724

170.314(c)(i) certification for a Modular EMR (CQM Data Warehouse) - Follow up question

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      Capture is C1. It requires certifying a provider data entry system. Import is part of C2 calculate. Therefore, data warehouses and data registries that do not have a provider data entry system for all data elements, but rather import QRDA1, should certify to only C2 and C3.

      The reason for modular certification is to allow for separating the certification requirements C1 (capture), C2 (calculate) and C3 (report) as appropriate. The policy principle is that providers can choose a suite of certified products that are interoperable, so that they use end for end technology leveraging more than one CERH technology. For a provider to attest for eCQM, he/she must input that data (capture) directly into CERHT, it can't be abstracted from paper and put into a registry or other data solution. C1 (capture)- is the certification requirement to test that the CERHT has the provider data entry screens to input the data in the workflow. The CERHT for C1 can then export the data a for another CERHT to import for calculation (C2) and reporting (C3). Therefore, data warehouses and registries without a tool for provider data entry should certify to import/calculate (C2) and report (C3) rather than capture (C1). Import is part of the C2 (calculate) and the test procedure tests the ability to take in an already created QRDA1 file.
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      Capture is C1. It requires certifying a provider data entry system. Import is part of C2 calculate. Therefore, data warehouses and data registries that do not have a provider data entry system for all data elements, but rather import QRDA1, should certify to only C2 and C3. The reason for modular certification is to allow for separating the certification requirements C1 (capture), C2 (calculate) and C3 (report) as appropriate. The policy principle is that providers can choose a suite of certified products that are interoperable, so that they use end for end technology leveraging more than one CERH technology. For a provider to attest for eCQM, he/she must input that data (capture) directly into CERHT, it can't be abstracted from paper and put into a registry or other data solution. C1 (capture)- is the certification requirement to test that the CERHT has the provider data entry screens to input the data in the workflow. The CERHT for C1 can then export the data a for another CERHT to import for calculation (C2) and reporting (C3). Therefore, data warehouses and registries without a tool for provider data entry should certify to import/calculate (C2) and report (C3) rather than capture (C1). Import is part of the C2 (calculate) and the test procedure tests the ability to take in an already created QRDA1 file.

      I had posed the following question: Please clarify that for MODULAR certification of a Clinical Data Warehouse EMR that, under the 'Capture' section 170.314(c)(1), the manual data entry (from the HTML document generatd by Cypress) is NOT required and that the use of the Import of QRDA CAT 1 (from the XML document generated by Cypress) is an acceptable method to meet the 170.314(c)(1) certification requirement. All previous posts have been respondng to the FULL EMR Certification, not the MODULAR EMR Certification.

      The response was that for modular certification 170.314(c)(2) and 170.314(c)(3) it was not necessary to demonstrate 170.314(c)(1) - capture or (ii) - export but that 170.314(c)(2) - import, would need to be demonstrated. This makes sense if the modular EMR is NOT certifying to the 170.314(c)(1) criteria. My question was more specific, which is if the modular EMR IS certifying to the 170.314(c)(1) criteria (Capture and Export) then is it acceptable to certify to the 170,314(c)(1) - Capture, by demonstrating the consumption of the QRDA L1 document only? Many Data Warehouse vendors support only capture of clinical data by electronic means and do not support manual data entry via a user interface. So, my question is specific to 170.314(c)(1) and if the consumption (capture) of clinical data certification can be met by the import of the QRDA L1 document and NOT the manual data entry which would be typical in a full EMR certification? Thank you!

            kevin.larsen Kevin Larsen (Inactive)
            moderator.ccda Moderator - C-CDA (Inactive)
            Kevin Larsen (Inactive), Maria Michaels (Inactive), Robert Dingwell (Inactive), Saul Kravitz (Inactive)
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