Clarifications:
- The specific requirements in provisions (g)(6)(i)-(iv) can be demonstrated in tandem.
- This certification criterion focuses on the data expressed in the USCDI.
- If the scope of the certification includes more than one certification criterion with C-CDA creation required, C-CDA creation performance only has to be demonstrated once for each C-CDA document template (e.g., C-CDA creation performance to the Continuity of Care Document (CCD) template would not have to be demonstrated twice if the Health IT Module presents for certification to both the Transitions of care and Data export criteria). [see also 80 FR 62674]
- In combination with the C-CDA R2.1 standard, developers certifying to the USCDI must follow the guidance and templates provided in HL7® CDA® R2 IG: C-CDA Templates for Clinical Notes R2 Companion Guide, Release 2, for implementation of the C-CDA Release 2.1 standard for the period leading up to and including December 31, 2025 or must follow guidance and templates provided in HL7® CDA® R2 IG: C-CDA Templates for Clinical Notes R2 Companion Guide, Release 4.1. For example, details on how to structure and exchange Clinical Notes are included in the C-CDA Companion Guide.
- In order to mitigate potential interoperability errors and inconsistent implementation of the HL7® IG for CDA® Release 2: Consolidated CDA Templates for Clinical Notes, Draft Standard for Trial Use, Release 2.1, ONC assesses, approves, and incorporates corrections as part of required testing and certification to this criterion. [see Health IT Certification Program Overview] Certified health IT adoption and compliance with the following corrections are necessary because they implement updates to vocabularies, update rules for cardinality and conformance statements, and promote proper exchange of C-CDA documents. There is a 90-day delay from the time the CCG has been updated with the ONC-approved corrections to when compliance with the corrections will be required to pass testing (i.e., ETT Message Validator). Similarly, there will be an 18-month delay before a finding of a correction’s absence in certified health IT during surveillance would constitute a non-conformity under the Certification Program.
- C-CDA files created during testing (using test data) will be retained by National Voluntary Laboratory Accreditation Program (NVLAP)-Accredited Testing Labs and contributed to an ONC-maintained repository. [see also 80 FR 62675]
- Consistent with Executive Order (EO) 14168 and OPM guidance, Health IT Modules certifying and/or currently certified to certification criteria that cross-reference the USCDI standard at 45 CFR 170.213 are only required to demonstrate the capability to categorize data on individuals for the sex data element in accordance with the following SNOMED CT® codes:
- 248152002 |Female (finding)| and
- 248153007 |Male (finding)|
- Further, these Health IT Modules are no longer required to support the following USCDI data elements for purposes of certification:
- Sexual orientation in USCDI version 4;
- Gender identity in USCDI version 4;
- Sex parameter for clinical use in USCDI version 5;
- Name to use in USCDI version 5;
- Pronouns in USCDI version 5.
- Through the C-CDA Patch Process, the HL7® Structured Documents Work Group (SDWG) approves C-CDA “patches”, which are corrections for issues with the C-CDA implementation guide (C-CDA IG) and companion guides. C-CDA “patches” include corrections for issues such as ambiguous requirements and requirements incompatible with real world deployment. Similar to C-CDA “patches” are C-CDA “additional guidance”. C-CDA “additional guidance” approved by the SDWG indicates guidance included in a newer version of the C-CDA IG or companion guide as being relevant to a previous version of the C-CDA IG or companion guide. A C-CDA “patch” may require a code change to correct errors or ambiguities in the guide, while “additional guidance” is purely clarifying and does not require any code changes. Though C-CDA “patches” and “additional guidance” are not required for certification purposes (unless indicated in the Certification Companion Guide), health IT developers may optionally implement C-CDA “additional guidance” in their Health IT Module and still be conformant with § 170.315(g)(6) criterion requirements.
- More information regarding the C-CDA Patch Process and C-CDA “patches” and “additional guidance” approved by the SDWG is available on the HL7® Confluence pages of C-CDA 'Patch' Process and Approved Patches and Additional Guidance.