SDWG discussed on 12/6/18. We believe "CDA on FHIR" should be an implementation guide, with (perhaps several) profiles for ClinicalDocument, where ClinicalDocument contains everything needed to represent a CDA ClinicalDocument. Currently, the "ClinicalDocument" profile does not contain nearly enough to represent a CDA ClinicalDocument.

After this update is done, C-CDA on FHIR could be updated to be a profile based on the "ClinicalDocument Profile", and consolidate the constraints based on what's defined in the ClinicalDocument profile.

Next step: Additional updates to the "ClinicalDocument" profile to include constraints that would make a complete clinical document (see C-CDA on FHIR for guidance).