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§ 170.315(f)(7)
Transmission to public health agencies — health care surveys
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Certification Companion Guide
Test Procedure
Certification Companion Guide
v1.4
View Changelog
Issued Date:
03-11-2024
07-23-2025
This Certification Companion Guide (CCG) is an informative document designed to assist with health IT product certification. The CCG is not a substitute for the requirements outlined in regulation and related ONC final rules. It extracts key portions of ONC final rules’ preambles and includes subsequent clarifying interpretations. To access the full context of regulatory intent please consult the
Certification Regulations
page for links to all ONC final rules or consult other regulatory references as noted. The CCG is for public use and should not be sold or redistributed.
Quick Overview
Required Updates
None
Design and Performance
Additional Criterion Information
Base EHR Definition
Not Included
Real World Testing
Yes
Insights Condition
No
SVAP Versions
Yes
CLARIFICATIONS
REGULATORY
STANDARDS
DEPENDENCIES
RESOURCES
CHANGELOG
IN THIS SECTION
Certification Clarifications
Technical Explanations and Clarifications
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Technical outcome – Health IT can create health care survey data for electronic transmission in compliance with all mandatory elements and requirements of the HL7® CDA National Health Care Surveys (NHCS) Implementation Guide (IG).
Health IT Modules certified to the
45 CFR 170.315(f)(7)
“Transmission to public health agencies—health care surveys" criterion using the
HL7 CDA® R2 Implementation Guide: National Health Care Surveys (NHCS), Release 1, DSTU Release 1.2 – US Realm
may retain their certified status until required to recertify according to the ONC Health IT Certification Program. Health IT developers newly certifying or recertifying Health IT Modules to the criterion at 45 CFR 170.315(f)(7) are required to use the standards referenced by
45 CFR 170.315(f)(7)
or available via the
Standards Version Advancement Process (SVAP)
For the public health certification criteria in § 170.315(f), health IT will only need to be certified to those criteria that are required to meet the measures the provider intends to report on to meet Objective 8: Public Health and Clinical Data Registry Reporting.
ONC clarified in the 2015 Edition Final Rule that the entire IG would be covered as part of certification. [
80 FR 62669
] ONC further clarifies that certification to each survey within the IG would be based on the selection of the health IT developer. ONC expects that such selection would be based on the healthcare setting that the Health IT Module presented for certification is intended to support. To illustrate, a Health IT Module designed to support providers practicing in:
An office setting would be presented for certification to NAMCS.
A hospital-based outpatient setting would be presented for certification to NHAMCS with the appropriate IG-identified outpatient constraints.
An emergency department would be presented for certification to NHAMCS with the appropriate IG-identified emergency department constraints.
Health IT developers can choose to use the flexibility of the Standards Version Advancement Process (SVAP) to use more advanced version(s) of standard(s) than the version(s) incorporated by reference in the regulation for this certification criterion. To comply with the Maintenance of Certification requirement in § 170.405(b), a developer that chooses to pursue such updates must include in their Real World Testing plan each Certified Health IT Module updated to newer version(s) of any standard(s) prior to August 31 of the year in which their updates were made and test each Module the following calendar year for conformance to all applicable criteria within its scope, including the newer version(s) of any standard(s).
Developers updating their already Certified Health IT Modules who choose to leverage the SVAP flexibility will be required to provide advance notice to all affected customers and its ONC-ACB. To be open and transparent to the public, health IT developers must also provide its ONC-ACB with a publicly accessible hyperlink to the SVAP Notice to be published with the Module on the ONC Certified Health IT Product List (CHPL).
STANDARDS REFERENCED
§ 170.205(s)(1)
HL7® Implementation Guide for CDA® Release 2: National Health Care Surveys (NHCS), Release 1 – US Realm
Errata for NHCS V1.0
Regulation Text
§ 170.315 (f)(7) Transmission to public health agencies – health care surveys—
Create health care survey information for electronic transmission in accordance with the standard specified in § 170.205(s)(1).
Standards & References
The following standards are referenced within the certification criteria for:
§ 170.315(f)(7) Transmission to public health agencies — health care surveys
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Standard
Paragraph
§ 170.205(s)(1)
HL7® Implementation Guide for CDA® Release 2: National Health Care Surveys (NHCS), Release 1 – US Realm
Referenced in the Following:
§170.315(f)(7)
SVAP-approved Versions:
HL7® CDA® R2 Implementation Guide: National Health Care Surveys (NHCS), R1 STU Release 3.1 - US Realm
Errata for NHCS V1.0
Referenced in the Following:
§170.315(f)(7)
§170.315(f)(7)
Applies to entire criterion
§ 170.205(s)(1)
HL7® Implementation Guide for CDA® Release 2: National Health Care Surveys (NHCS), Release 1 – US Realm
Errata for NHCS V1.0
Certification Dependencies
IN THIS SECTION
§ 170.405
Real World Testing
Products certified to this criterion must complete requirements outlined for the Real World Testing Conditions and Maintenance of Certification.
Note: Enforcement discretion has been issued for CY 2025–2026. Refer to the
Enforcement Discretion Notices
for full details.
Privacy and Security
This certification criterion was adopted at § 170.315(f)(7). As a result, an ONC Authorized Certification Body (ONC-ACB) must ensure that a product presented for certification to a § 170.315(f) criterion includes the privacy and security criteria (adopted in § 170.315(d)) within the overall scope of the certificate issued to the product.
The privacy and security criteria (adopted in § 170.315(d)) do not need to be explicitly tested with this specific paragraph (f) criterion unless it is the only criterion for which certification is requested.
As a general rule, a product presented for certification only needs to be tested once to each applicable privacy and security criterion (adopted in § 170.315(d)) so long as the health IT developer attests that such privacy and security capabilities apply to the full scope of capabilities included in the requested certification. However, exceptions exist for § 170.315(e)(1) “View, download, and transmit to 3rd party (VDT)” and (e)(2) “Secure messaging,” which are explicitly stated.
§ 170.315(d)(2)(i)(C) is not required if the scope of the Health IT Module does not have end-user device encryption features.
For more information on the approaches to meet these Privacy and Security requirements, please download the Privacy and Security CCG below:
Privacy and Security CCG
If choosing
Approach 1
Authentication, access control, and authorization (§ 170.315(d)(1))
Auditable events and tamper-resistance (§ 170.315(d)(2))
Audit reports (§ 170.315(d)(3))
End-user device encryption (§ 170.315(d)(7))
Encrypt authentication credentials (§ 170.315(d)(12))
Multi-factor authentication (MFA) (§ 170.315(d)(13))
If choosing
Approach 2
For each applicable privacy and security certification criterion not certified for Approach 1, the health IT developer may certify using system documentation that is sufficiently detailed to enable integration such that the Health IT Module has implemented service interfaces for each applicable privacy and security certification criterion that enable the Health IT Module to access external services necessary to meet the requirements of the privacy and security certification criterion. Please see the
21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program
Final Rule at
85 FR 25710
for additional clarification.
Design and Performance
The following design and performance certification criteria (adopted in § 170.315(g)) must also be certified in order for the product to be certified.
Quality management system (§ 170.315(g)(4))
: When a single quality management system (QMS) is used, the QMS only needs to be identified once. Otherwise, the QMS’ need to be identified for every capability to which it was applied.
Accessibility-centered design (§ 170.315(g)(5))
: When a single accessibility-centered design standard is used, the standard only needs to be identified once. Otherwise, the accessibility-centered design standards need to be identified for every capability to which they were applied; or, alternatively, the developer must state that no accessibility-centered design was used.
Resources
The following resources can offer assistance or additional information:
§ 170.315(f)(7) Transmission to public health agencies — health care surveys
PDF DOCUMENT
Real World Testing Resource Guide
2025-10-01
PDF DOCUMENT
Real World Testing Fact Sheet
Certification Companion Guide Changelog
The following changelog applies to:
§ 170.315(f)(7)Transmission to public health agencies — health care surveys
Changelog functionality is not available.
Revision History
Version #
Description of Change
Version Date
1.0
Initial publication
03-11-2024
1.1
Removed “HL7® CDA® R2 Implementation Guide: National Health Care Surveys (NHCS), R1 DSTU Release 1.2 – US Realm” as an optional standard as newer versions are available for certification via SVAP.
06-04-2024
1.2
Standards Referenced updated to reflect 2024 Approved SVAP Standards.
08-19-2024
1.3
Added clarification regarding health IT developers currently certified to 45 CFR 170.315(f)(7) using “
HL7® CDA® R2 Implementation Guide: National Health Care Surveys (NHCS), R1 DSTU Release 1.2 – US Realm
11-26-2024
1.4
Added update to Certification Dependencies section to reflect recent Real World Testing enforcement discretion notice.
07-23-2025
Test Procedure
v1.1
View Changelog
Issued Date:
03-11-2024
11-26-2024
This Test Procedure illustrates the test steps required to certify a Health IT Module to this criterion. Please consult the most recent ONC Final Rule on the
Certification Regulations
page for a detailed description of the certification criterion with which these testing steps are associated. ONC also encourages developers to consult the Certification Companion Guide in tandem with the test procedure as it provides clarifications that may be useful for product development and testing.
Quick Overview
Required Updates
None
Design and Performance
Additional Criterion Information
Base EHR Definition
Not Included
Real World Testing
Yes
Insights Condition
No
SVAP Versions
Yes
TESTING STEPS
TOOLS AND DATA
TESTING COMPONENTS
CHANGELOG
IN THIS SECTION
View Regulation Text
Testing Steps
Note: The test step order does not necessarily prescribe the order in which the tests should take place.
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Testing Steps
System Under Test
The health IT developer identifies which of the survey type settings (Outpatient, Emergency Department) are applicable to the system under test. The user enters ONC-supplied patient-level test data that will be used to generate the health care survey information for each of the test cases identified as applicable (e.g., Outpatient (OP), Emergency Department (ED)) from the ONC: National Health Care Surveys (NHCS) Validator. All test cases are required that apply to the care setting(s) supported by the system under test.
The Health IT Module creates a health care survey document in accordance with the HL7® CDA
National Health Care Surveys (NHCS) IG for each test case.
Test Lab Verification
The tester verifies the Health IT Module creates the source health care survey content correctly through visual inspection of the system under test using the test data associated with the selected test case.
The tester verifies the health care survey document is correct and without omission:
The tester imports the health care survey CDA
document into the test tool for validation and uses the Validation Report produced by the test tool to verify that the Health IT module passes without error to confirm that the health care survey information document conforms to the HL7® CDA
National Health Care Surveys (NHCS) IG.
The tester uses the validation report to verify that the health care survey information document (CDA
document) generated by the Health IT Module is correct, and uses the specified value sets.
If using the context-based tool, use the tool to verify that the CDA
document reflects the data entered into the Health IT Module. Otherwise, use visual inspection of the CDA
document XML and human readable content to verify that the CDA
document reflects the data entered into the Health IT Module.
TEST TOOL DOCUMENTATION
Testing Tools
§ 170.315(f)(7) Transmission to public health agencies — health care surveys
HL7® CDA® National Health Care Surveys (Release 3.1) Validator for 2024 SVAP
(Coming soon)
HL7® CDA® National Health Care Surveys (Release 3.0) Validator for 2020 SVAP
The NIST/CDC CDA Test Suite supports validation testing of the HL7 National Health Care Surveys CDA Release 3 specification.
HL7® CDA® National Health Care Surveys (Release 1.2) Validator
The purpose of this site is to facilitate testing of National Health Care Surveys CDA XML documents conformant to HL7 CDA® R2 Implementation Guide: National Health Care Surveys Release 1, DSTU Release 1.2 – US Realm, August 2016, Draft Standard for Trial Use (DSTU) for certification and other purposes.
HL7® CDA National Health Care Surveys (Release 1.0) Validator
The purpose of this site is to facilitate testing of National Health Care Surveys CDA XML documents conformant to HL7 Implementation Guide for CDA® Release 2: National Health Care Surveys (NHCS), Release 1 - US Realm HL7 Draft Standard for Trial Use (DSTU), December 2014 for certification and other purposes.
Test Data
Test data for implementation and validation.
HL7® CDA® NHCS Release 3.1 Implementation Guide (Coming soon)
HL7® CDA® NHCS Release 3.1 Test Data (Coming soon)
HL7® CDA® NHCS Release 3.0 Implementation Guide
HL7® CDA® NHCS Release 3.0 Test Data
HL7® CDA® NHCS Release 1.2 Implementation Guide
HL7® CDA® NHCS Release 1.2 Test Data
HL7® CDA® NHCS Release 1.0 Implementation Guide
HL7® CDA® NHCS Release 1.0 Test Data
Testing Components
§ 170.315(f)(7) Transmission to public health agencies — health care surveys
Documentation may be used as a method to demonstrate conformance but is not required for this criterion. Health IT developers may optionally provide documentation to supplement other testing methods.
Visual inspection is an approved method to demonstrate conformance. Most commonly, this will be accomplished via a live demonstration of functionality that meets the criterion.
Testing tools indicate that a test tool(s) exists and must be used to test a portion or all of a Health IT Module's conformance to the criterion.
Indicates that the Standards Version Advancement Process (SVAP) is applicable to the criterion.
Test Data
The test data for this criterion is provided within the testing tools tab. Click the link below to be directed to the testing tools tab.
Review Test Data
Test Method Changelog
The following changelog applies to:
§ 170.315(f)(7)Transmission to public health agencies — health care surveys
Changelog functionality is not available.
Revision History
Version #
Description of Change
Version Date
1.0
Initial publication
03-11-2024
1.1
Updated links to testing tools for 2020 and 2024 SVAP. Updated “System Under Test” and “Test Lab Verification” steps to reference the HL7 CDA National Health Care Survey (NHCS) implementation guide more generally to allow the advancement of standards versions without having to make updates to referenced standards in the test steps. Updated links to test data.
11-26-2024
The following design and performance certification criteria (adopted in § 170.315(g)) must also be certified in order for the product to be certified.
Additional Criteria:
§ 170.315(g)(4)
Quality management system
Description:
When a single quality management system (QMS) is used, the QMS only needs to be identified once. Otherwise, the QMS’ need to be identified for every capability to which it was applied.
§ 170.315(g)(5)
Accessibility-centered design
Description:
When a single accessibility-centered design standard is used, the standard only needs to be identified once. Otherwise, the accessibility-centered design standards need to be identified for every capability to which they were applied; or, alternatively, the developer must state that no accessibility-centered design was used.
Loading Privacy & Security content...
Standards Version Advancement Process (SVAP)
The Standards Version Advancement Process (SVAP) permits health IT developers to voluntarily update health IT products certified under the ONC Health IT Certification Program (Certification Program) to newer versions of adopted standards as part of the "Real World Testing" Condition and Maintenance of Certification requirement (§ 170.405) of the 21st Century Cures Act.
Learn More About SVAP
SVAP Approved Version:
HL7® CDA® R2 Implementation Guide: National Health Care Surveys (NHCS), R1 STU Release 3.1 - US Realm
Related to standard reference: § 170.205(s)(1)
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