Comments to RIN 0955-AA02

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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"

Context

Comments are due at this site before 2021-01-04. Attachments should be in Microsoft Word, Microsoft Excel, or Adobe PDF; however, they prefer Microsoft Word.

  • 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 (85 FR 25642), and became effective on June 30, 2020

Comments

  1. 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 this location and has stated to develope Software Compliance Attestations 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.
  2. Section 170-315 (certification criteria)