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Thursday, May 19, 2011

What is a valid C32 for MeaningfulUse

This was a hot topic as a result of ballot comment on the CDA Consolidation guide. The question was: Why is a procedures section or results section required if you have none. The suggestion was that this was required under Meaningful Use based on the requirments of thse suggestions in conformance tests from NIST. The conformance tests are to show that the document creator complies with the certification requirements, not that the instance meets the requirements of the stated standards and implementation guides. When in doubt, read the rules.

So, will every C32 sent under meaningful use have results and procedures? I would assert not. Will every certified product be able to produce those where they may be required? Yes.

That's the difference between a functionally valid EHR that produces C32 documents and a valid C32 instance.


  1. Thanks for posting this. I find myself explaining this many times over, so it is good to see it posted on a well read blog.

    One note I would make for the sake of clarity is that procedures are not a certification requirement for C32 Meaningful Use Stage 1. MU Stage 1 required sections are medications, (medication) allergies, problems, and results. This is of course subject to addition for Stage 2 and beyond.

  2. I added you to my following twitter list this am, you asked a question, I could not reply b/c you are not following me. Most of my web presence is in fiber arts. My real job is Health IT, standards and vocab. Just wanted to let you know I am not a spammer, or followed you by mistake. I am interested in the Twitter chats. Laritza aka YorkSett

  3. Excellent point, Keith. I too have to explain that what the EHR must be capable of producing for a certification test does not apply to every patient-specific instance of a CCD generated in actual exchanges.

    Clarification: While PROCEDURES are not required in C32 for ambulatory EHRs, they ARE required for HOSPITAL EHRs. See ONC Final Rule sections 170.306(d) and (f). The definition of "which kind of procedures" was never stated clearly, so the presumption is that it is "significant" procedures (such as surgeries) but not others such as venipunctures.

  4. Thank you David. That was my omission. I am glad you mentioned it.