From the 170.314(c) Test Procedure page 7:
"It is acceptable for an EHR SUT to "capture" QRDA Category 1 XML files in an automated way for their "capture and export" as long as the information is displayed in the appropriate places in the transaction system. For example, if a problem of the data type "problem list" is imported via a QRDA Category 1 XML file, it needs to be seen in the user interface in the problem list section. "

It does not appear that the ONC properly considered the consequences of making this change in the test procedure document, but the net effect is to take a system that has many validations and protections around how data is entered into a system and to remove all those protections merely to meet a certification requirement.

There is simply not enough information presented in a QRDA I document to effectively and safely import that data into a patient record in a real clinical scenario in a meaningful way.

The ONC appears to be asking me to take my real world, production EHR system, that is used in a real clinical environment that protects both patient and provider by ensuring proper data, entered in the proper way, and turn it into a toy system that does things in a half baked way that would never pass in a real life scenario, just so I can meet their certification program.

It is unacceptable that I have to relax the requirements in my system to meet a certification, just because the certification tool that is being used to test my system is limited to fake, conjured up scenarios that do not reflect real life.

Data import and merge from a CCDA document is required functionality in certified systems. It would make much more sense to use this mechanism, than to impose an additional import requirement using a document that is not clinically relevant and provides less data.

It should be completely acceptable for my system to import QRDA I documents, do my calculations off of those documents, then present that back to the test tool in summary form, without having to import that data into my transactional system.

It is also completely ridiculous for me to have to import a valid QRDA I document and then re-export that same data from my system in QRDA I format.
I should be able to take the QRDA I that was input into my system and simply output that same document at the time the QRDA I files are needed.
Unnecessary reprocessing of data is error prone and wasteful. Since I already have to prove that I can export QRDA I documents for a different part of the measure it seems silly to require the import of QRDA I documents then turn right around and export what is essentially going to be the same documents.

Please provide justification for the import requirements in the test procedure. They are both onerous and harmful.

Thank you for your considerations in these matters.