Would an EHR technology that allows manual entry of problem, medication, or laboratory test data into an education search tool be able to satisfy the “other-than-Infobutton1 -enabled” capability required by the “patient-specific education resources” certification criterion at 45 CFR 170.314(a)(15)(ii)?2

  1. For both capabilities within the certification criterion (170.314(a)(15)(i) and (ii)), we interpret there to be 3 specific conditions that need to be satisfied:
  2. EHR technology must be able to "electronically identify" education resources;
  3. The education resources must be "patient-specific;" and
  4. The education resources must be based on data included in the patient's problem list, medication list, and laboratory tests.

While the alternative method (“By any means other than the method specified in paragraph (a)(15)(i)”) provides EHR technology developers with significant flexibility, the three conditions above must be satisfied regardless of the method implemented. Manual entry could be used to address condition #3 so long as the data entered is equivalent to the data that is included in the patient’s problem list, medication list, and laboratory tests.

The following examples illustrate an acceptable and unacceptable approach to meeting 170.314(a)(15)(ii)’s requirement:

Acceptable example:

The alternative method provided by the EHR technology enables a user to manually enter problem, medication, or laboratory test data from the patient’s respective lists and then electronically identifies education materials that are patient-specific. In other words, if an EP uses an alternative method with Patient A and Patient B, both of whom are on the same medication but have different demographic characteristics (e.g., male vs. female; 21 vs. 65), the alternative method must be capable of electronically identifying patient-specific education materials for Patient A and B individually, based on the manually entered data of each patient.

Unacceptable example:

The alternative method provided by the EHR technology presents the user with an education resource search tool that allows for manual entry of patient problems, medications, and laboratory tests and returns education materials electronically, but cannot differentiate the materials in such a way as to make them “patient-specific.”

  1. HL7 Context-Aware Knowledge Retrieval (“Infobutton”) Standard
  2. This FAQ has been updated to reflect the correct data elements listed in § 170.314(a)(15). Specifically, we replaced “medication allergy” with “laboratory tests.”