Comment:

Not clear if/how provenance is represented in this FHIR Implementation Guide. Provenance (who, what, when, where, why) is essential at: 1) point of origination (at the source, for newly captured content), 2) point of update (for newly updated content, preserving previous content and its provenance).

Who = subject of care/information (typically the patient)

Who = performer of action taken

Who = author of information captured or updated

Who = organization

What = action taken

When = date/time of action taken

When = date/time of information capture or update

Where = physical location of action taken

Where = physical location of information capture or update

Where = network address and/or device ID where information captured or updated

Why = rationale, purpose of action taken

Why = rationale, purpose of information capture or update

Granularity of provenance (e.g., binding authorship to content) may be at the dataset or element level.

Summary:

Clarify provenance