If my EHR technology is capable of submitting batch files to an immunization registry using the applicable adopted standards, is that sufficient for demonstrating compliance with the certification criterion specified at 45 CFR 170.302(k) or170.314(f)(2) (adopted as part of the 2011 and 2014 Edition EHR certification criteria, respectively)?
The certification criteria at 45 CFR 170.302(k) and 170.314(f)(2) do not specify, and are not intended to specify, when submissions should be made or the periodicity of the submissions. Consequently, submitting batch files to an immunization registry, provided that they are formatted according to the adopted standards referenced by the certification criteria at 45 CFR 170.302(k) and 170.314(f)(2), is not prohibited by these certification criteria and would be acceptable.