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Healthcare Compliance Newsletter – October 2021

Healthcare Compliance Newsletter – October 2021

In this issue:
  1. Drummond Pilots New Pediatric EHR Testing, Certification
  2. Inpatient EHRs: You May Need to Certify Additional Criteria
  3. Real World Test (RWT) Plan Due Nov. 15
  4. Reduced ACSR 2022 Fee Offer Available Through Dec. 31
  5. RWT Advisory Services – An Option Remains
  6. Expect an EPCS Audit That’s Reliable
Drummond Pilots New Pediatric EHR Testing and Certification

In December, Drummond Group will pilot our newest testing and certification program specifically designed for pediatric electronic health records (EHR). This latest Drummond Certified-branded program is a voluntary pediatric-focused certification aimed at improving child health outcomes by raising the bar of EHR functionalities deployed in inpatient and ambulatory pediatric settings.

This new program is based on the Office of the National Coordinator for Health Information Technology (ONC)’s recommended 10 pediatric functions in its 21st Century Cures Final Rule. It is designed to further expand the ONC recommendations by including a broader and robust set of pediatric functional requirements.

Scheduled for general launch during the first quarter in 2022, it will provide developers a means to distinguish themselves in the marketplace as having robust pediatric EHR certification functionality. In addition, Drummond’s Pediatric EHR Testing and Certification program is expected to leverage the standards-related work numerous pediatric clinicians have developed.

Through the program’s development, our team has helped facilitate an updated HL7® Pediatric Care Health IT Functional Profile standard (see details). This profile specification was balloted last month and is slated for publication in January 2022. Comments related to the specification are welcomed during the open comment period.

We are currently seeking EHR software developers willing to collaborate with Drummond in the program’s review and provide critical feedback from the developer community. If you are interested in joining the piloting of this new program or participating in pediatric testing and certification when the program is launched, please contact Timothy Bennett at for more information.

Inpatient EHRs: You May Need to Certify Additional Criteria!

New 2022 CMS rules for IPPS and LTCH PPS were recently published. These rules were revised to require Eligible Hospitals/Critical Access Hospitals to report on at least four public health measures (up from two in 2021):

  1. §170.315(f)(1) Transmission to Immunization Registries
  2. §170.315(f)(2) Transmission to Public Health Agencies — Syndromic Surveillance
  3. §170.315(f)(3) Transmission to Public Health Agencies — Reportable Laboratory Tests and Value/Results
  4. §170.315(f)(5) Transmission to Public Health Agencies — Electronic Case Reporting

It is expected these four measures would assist the current recovery as well as make public health agencies (PHAs) better prepared for future health threats. The measures also will enable nationwide syndromic surveillance for early warning of emerging outbreaks and threats; automated case and laboratory reporting for fast public health response; and local and national visibility on immunization uptake so PHAs can tailor vaccine distribution strategies.

Inpatient EHR users need certified health IT with all four of these public health criteria. Additional public health criteria may be certified, but these are the minimum beginning in 2022. If an inpatient EHR product is not already certified for all four public health criteria, please register it for additional testing as soon as possible. Registration may be completed in the Drummond portal or on our website here.

Questions? Please contact

Real World Test (RWT) Plan Due Nov. 15

As a requirement of the 21st Century Cures Act Final Rule, health IT developers certified under the 2015 Edition must submit a Real World Test Plan for each of their certified product(s) this year. Drummond has designated a due date of Nov. 15, 2021.

For more information, please visit the ONC Real World Testing page. Questions regarding the ONC’s RWT requirement? Contact us at

Reduced ACSR 2022 Fee Offer Available Through Dec. 31!

Drummond is offering a reduced Annual Certification Surveillance Renewal (ACSR) fee for 2022.

This annual fee – typically billed and due in January at a rate of $4,500 – will be reduced by 15 percent to $3,825 if payment reaches Drummond in 2021 (extended from Oct. 31).

To take advantage of this offerfill in all fields on this form and list each certified product you wish to include for the discount. An individual invoice reflecting the reduced rate for each product will be sent from Drummond’s finance department to the accounts payable contact indicated on your form.

Questions? Please contact

RWT Advisory Services – An Option Remains!

For Drummond clients interested in additional guidance for creating Real World Test (RWT) plans, the Advisory Services team has designed a collateral packet that may be licensed for a one-time fee.

This collection of RWT guidance documents was created to help your organization write a test plan in time to meet Drummond ACB’s upcoming Nov. 15 submission deadline. It has been culled from the materials provided to customers in our Advisory Services program and contains much of the same guidance. The packet also includes the option to engage Drummond for a call to review the contents.

The Advisory Services team experienced a high demand for its full consultancy services and was unable to fulfill all requests for the remainder of 2021. However, full engagement opens again in January for customers needing planning assistance for executing RWT plans, as well as writing results reports. For more information, please contact John Valutkevich.

The services offered by Drummond Advisory Services are separate and distinct from the Drummond Group Test Lab and Certification Body. The purpose of Drummond Advisory Services is to provide expert support and guidance for the planning, analysis, and execution of certification activities; it does not negate the steps or required actions of the certification process. Use of Drummond Advisory Services does not guarantee successful ONC Health IT testing or certification.

Expect an EPCS Audit That’s Reliable

Did your EPCS auditor go AWOL recently? Our EPCS experts – Aaron Gomez and Patrick Paschall – have tested more than 200 e-prescribing applications. Drummond’s program begins with a thorough review of the Drug Enforcement Administration (DEA) regulations so your team has a firm understanding of the requirements.

Contact us at on how you, too, can test and certify your EHR product. Expect an EPCS audit experience that’s reliable and based on integrity, trust and years of experience.

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