Comments to RIN 0955-AA02 - Revision history

Tomjones: /* Comments */

2021-02-18T02:03:53Z

Comments

← Older revision		Revision as of 02:03, 18 February 2021
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	# The Certificate of Compliance (CoC). - Basis and scope - (sec. 170.400 or earlier if appropriate). Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Basis and scope - (sec. 170.400 or earlier if appropriate). Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
	# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"		# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"

			[[Category:Health]]

Tomjones: /* Comments */

2020-11-08T22:13:07Z

Comments

← Older revision		Revision as of 22:13, 8 November 2020
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	==Comments==		==Comments==
	# The Certificate of Compliance (CoC). - Basis and scope - (sec. 170.400~~) (~~or earlier if appropriate. Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Basis and scope - (sec. 170.400 or earlier if appropriate). Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
	# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"		# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"

Tomjones: /* Comments */

2020-11-08T22:12:47Z

Comments

← Older revision		Revision as of 22:12, 8 November 2020
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	==Comments==		==Comments==
	# The Certificate of Compliance (CoC). - Basis and scope - (sec. 170.400) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Basis and scope - (sec. 170.400) (or earlier if appropriate. Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
	# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"		# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"

Tomjones: /* Comments */

2020-11-08T22:12:13Z

Comments

← Older revision		Revision as of 22:12, 8 November 2020
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	==Comments==		==Comments==
	# The Certificate of Compliance (CoC). - ~~Information Blocking~~ - (sec. 170.~~401~~) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Basis and scope - (sec. 170.400) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
	# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"		# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"

Tomjones: /* Comments */

2020-11-08T21:58:10Z

Comments

← Older revision		Revision as of 21:58, 8 November 2020
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	==Comments==		==Comments==
	# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
	# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication"		# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication, through" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication WITHOUT USING"

Tomjones: /* Comments */

2020-11-08T21:56:12Z

Comments

← Older revision		Revision as of 21:56, 8 November 2020
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	==Comments==		==Comments==
	# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
	# Section 170-315 (certification criteria)		# Section 170.315 (certification criteria) (d)(13)(ii) current text. "When attesting “no,” the health IT developer may explain why the Health IT Module does not support authentication" suggested test "When attesting “no,” the health IT developer MUST explain HOW the Health IT Module ASSURES ADEQUATE authentication"

Tomjones: /* Context */

2020-11-08T21:44:45Z

Context

← Older revision		Revision as of 21:44, 8 November 2020
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	* However, the rules went into effect on 2020-11-04 and 2020-12-04.		* However, the rules went into effect on 2020-11-04 and 2020-12-04.
	* The IFC also updates certain standards in the Program, and makes necessary corrections and clarifications to the ONC Cures Act Final Rule, which was published in the Federal Register on May 1, 2020 ([https://www.federalregister.gov/citation/85-FR-25642 85 FR 25642]), and became effective on June 30, 2020		* The IFC also updates certain standards in the Program, and makes necessary corrections and clarifications to the ONC Cures Act Final Rule, which was published in the Federal Register on May 1, 2020 ([https://www.federalregister.gov/citation/85-FR-25642 85 FR 25642]), and became effective on June 30, 2020
			* References below are all to [https://ecfr.federalregister.gov/current/title-45/subtitle-A/subchapter-D 45 CFR Subtitle A Subchapter D].

	==Comments==		==Comments==
	# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
	# Section 170-315 (certification criteria)		# Section 170-315 (certification criteria)

Tomjones: /* Full Title */

2020-11-08T20:22:15Z

Full Title

← Older revision		Revision as of 20:22, 8 November 2020
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	==Full Title==		==Full Title==
	Comments to RIN 0955-AA02 at the Federal Register ~~Rull~~ on "Information Blocking and the ONC Health IT Certification Program: Extension of Compliance Dates and Timeframes in Response to the COVID-19 Public Health Emergency"		Comments to RIN 0955-AA02 at the Federal Register Rule on "Information Blocking and the ONC Health IT Certification Program: Extension of Compliance Dates and Timeframes in Response to the COVID-19 Public Health Emergency"

	==Context==		==Context==
	Comments are due at [https://www.federalregister.gov/documents/2020/11/04/2020-24376/information-blocking-and-the-onc-health-it-certification-program-extension-of-compliance-dates-and this site] before 2021-01-04. Attachments should be in Microsoft Word, Microsoft Excel, or Adobe PDF; however, they prefer Microsoft Word.		Comments are due at [https://www.federalregister.gov/documents/2020/11/04/2020-24376/information-blocking-and-the-onc-health-it-certification-program-extension-of-compliance-dates-and this site] before 2021-01-04. Attachments should be in Microsoft Word, Microsoft Excel, or Adobe PDF; however, they prefer Microsoft Word.

Tomjones: /* Comments */

2020-11-08T20:21:38Z

Comments

← Older revision		Revision as of 20:21, 8 November 2020
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	* The IFC also updates certain standards in the Program, and makes necessary corrections and clarifications to the ONC Cures Act Final Rule, which was published in the Federal Register on May 1, 2020 ([https://www.federalregister.gov/citation/85-FR-25642 85 FR 25642]), and became effective on June 30, 2020		* The IFC also updates certain standards in the Program, and makes necessary corrections and clarifications to the ONC Cures Act Final Rule, which was published in the Federal Register on May 1, 2020 ([https://www.federalregister.gov/citation/85-FR-25642 85 FR 25642]), and became effective on June 30, 2020
	==Comments==		==Comments==
	# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to ~~develope~~ [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. ~~This~~ approach to software applications in ~~the~~ user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develop [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. The addition of this proposed approach to software applications in user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
	# Section 170-315 (certification criteria)		# Section 170-315 (certification criteria)

Tomjones: /* Comments */

2020-11-08T19:40:34Z

Comments

← Older revision		Revision as of 19:40, 8 November 2020
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	==Comments==		==Comments==
	# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develope [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. This approach to software applications in the user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.		# The Certificate of Compliance (CoC). - Information Blocking - (sec. 170.401) Clearly applies to Software used by EHR. It is proposed that it be clarified that the certification for User Apps be a CoC and that a digital version be developed. The Kantara Initiative has published a draft candidate for this digital version as an implementor's report at [https://kantarainitiative.org/download/kantara-mobile-assurance-statement/ this location] and has stated to develope [[Software Compliance Attestation]]s to use to acquire the Certificate of Compliance. This approach to software applications in the user devices is considered to involve the least effort by the ONC and to yield the most consistent results across the technology community.
			# Section 170-315 (certification criteria)