Existing Wording: If the Documentation Templates and Rules (DTR) / Substitutable Medical Applications, Reusable Technologies (SMART) on FHIR application is executed using an app, the app will only have access to data specifically authorized by the organization as appropriate for use.

Proposed Wording: If the Documentation Templates and Rules (DTR) / Substitutable Medical Applications, Reusable Technologies (SMART) on FHIR application is executed using an app, the app will have access to data authorized by the organization as appropriate for use by the app, and accessible to the user. Note that, especially if a common SMART on FHIR app is used to deal with multiple prior auth decision types, and even if that is not the case, it is highly likely that the app will have the abiltiy to pull much more data than is needed. For example, if Observation.read capabilities are needed, the app will be able to pull Observations beyond what is actually needed for the prior auth.

Comment:

Everyone involved should be aware of the broad nature of SMART on FHIR access mechanisms.

Summary:

Everyone involved should be aware of the broad nature of SMART on FHIR access mechanisms.