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Q: Are quarterly attestations regarding SEDs, adaptations, product changes and complaints still required since the ONC also requires an attestation every 6 months?
A: Yes. The quarterly attestations are still required because they cover different information than the Cures Rule attestation. In fact, the quarterly attestations starting with Q3 2020 were expanded to cover all updates successfully made to support National Coordinator-approved newer versions of Secretary-adopted standards in certified health IT pursuant to the developers having voluntarily opted to avail themselves of the Standard Version Advancement Process flexibility. This also includes any new MFA use cases.
170.523(m) Adaptations and updates. On a quarterly basis each calendar year, obtain a record of:
- (1) All adaptations of certified Health IT Modules;
- (2) All updates made to certified Health IT Modules affecting the capabilities in certification criteria to which the “safety-enhanced design” criteria apply;
- (3) All uses cases for § 170.315(d)(13);
- (4) All updates made to certified Health IT Modules in compliance with § 170.405(b)(3); and
- (5) All updates to certified Health IT Modules and all certifications of Health IT Modules issued including voluntary use of newer standards versions per § 170.405(b)(8) or § 170.405(b)(9). Record of these updates may be obtained by aggregation of ONC-ACB documentation of certification activity.
SLI also requires reporting of complaints, nonconformities, and all product changes that occurred during the quarter if not already reported to us, to help ensure ongoing product compliance
Q: Can I submit documentation prior to testing?
A: Yes. Submitting required documentation prior to beginning the test procedure will give your proctor time to review and return any documents requiring additional information back to you. All required documentation should be submitted at least two business days prior to the scheduled test session.
Q: What Test Data requirements do I need to have in place for testing?
A: On the ONC website – Test Methods page (refer to the ONC links below), each public test procedure includes a testing component icon of “ONC Supplied Test Data.” Testing components are not included on the conformance methods for Attestation criteria; there is no ONC supplied test data for Attestation criteria.
The ”ONC Supplied Test Data” testing component icon will be crossed out if no ONC test data is supplied or will not be crossed out if there is ONC test data supplied that you will be required to enter for testing. Additional information regarding test data, including links to test data and testing tools, can be found on each test procedure by clicking on the Testing dropdown bar. Some test data should be entered prior to the test session and other test data must be entered during the remote interactive test session.
Q: Can I pretest certification criteria with an SLI Compliance Proctor?
A: We offer Pre-Certification Testing services for a fee. Contact the ATL Test Manager for details.
Q: How can I most effectively manage my testing time?
A: Careful preparation for each test procedure will help with time management; i.e.
- Thoroughly understand the requirements of each test criterion and ensure that you can fully demonstrate all required steps.
- Be familiar with any ONC testing tools required for testing.
- Prepare patients and/or login accounts required for each test procedure in advance.
- Enter as much test data in advance as is allowed by each test procedure.
- For criteria that require vendor supplied test data, plan and prepare patients and test data in advance.
- For criteria that require ONC supplied test data, be familiar with the ONC test data that will be entered.
- Conduct your own pretesting prior to your official test date, using ONC testing tools and testing each required step.
- During testing, if a step in a test procedure fails, have resources available to make appropriate fixes offline while continuing to test other steps or criteria. Plan to retest any failures after completing all untested test procedures first.
Q: Can I contact an SLI Compliance testing expert with questions?
A: Yes, support time is part of your contract. You will be assigned a test specialist to assist you with pre-test questions pertaining to the criteria you are requesting to test. If you wish to purchase additional support time, contact the Test Manager for details.
For additional information provided by the ONC please visit the official website of the ONC for Health Information Technology Program page.
ONC Resources
https://www.healthit.gov/topic/certification-ehrs/certification-health-it
https://www.healthit.gov/topic/certification-ehrs/program-resources
https://www.healthit.gov/topic/certification-ehrs/onc-health-it-certification-program-test-method
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