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  1. FHIR Specification Feedback
  2. FHIR-28712

If the CDS Service will be sending information to a payer or outside entity, the physicians needs to know/approve this.

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    • Icon: Change Request Change Request
    • Resolution: Persuasive with Modification
    • Icon: Highest Highest
    • CDS Hooks (FHIR)
    • 1.0 [deprecated]
    • Clinical Decision Support
    • (NA)
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      Agree with commenter, but believe that this issue is already addressed in the specification and in practice:

      Once a CDS Service provider is selected, the CDS Client vendor/provider negotiates the terms under which service will be provided. This negotiation includes agreement on patient data elements that will be prefetched and provided to the CDS Service, data elements that will be made available through an access token passed by the CDS Client, and steps the CDS Service MUST take to protect patient data and access tokens. The CDS Service can be registered as a client to the CDS Client authorization server, in part to define the FHIR resources that the CDS Service has authorization to access. These business arrangements are documented in the service agreement.

      https://cds-hooks.org/specification/current/#trusting-cds-services

      Propose adding to the Providing FHIR Resources to a CDS Service section, 4th paragraph:

      "Similarly, each CDS Client will decide what FHIR resources to authorize and to prefetch, based on the CDS Service discovery response's "prefetch" request and on the provider's assessment of the "minimum necessary." The CDS Client provider and the CDS Service provider will negotiate the set of FHIR resources to be provided, and how these data will be provided, as part of their service agreement."

       

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      Agree with commenter, but believe that this issue is already addressed in the specification and in practice: Once a CDS Service provider is selected, the CDS Client vendor/provider negotiates the terms under which service will be provided. This negotiation includes agreement on patient data elements that will be prefetched and provided to the CDS Service, data elements that will be made available through an access token passed by the CDS Client, and steps the CDS Service MUST take to protect patient data and access tokens. The CDS Service can be registered as a client to the CDS Client authorization server, in part to define the FHIR resources that the CDS Service has authorization to access. These business arrangements are documented in the service agreement. https://cds-hooks.org/specification/current/#trusting-cds-services Propose adding to the Providing FHIR Resources to a CDS Service section, 4th paragraph: "Similarly, each CDS Client will decide what FHIR resources to authorize and to prefetch, based on the CDS Service discovery response's "prefetch" request and on the provider's assessment of the "minimum necessary." The CDS Client provider and the CDS Service provider will negotiate the set of FHIR resources to be provided, and how these data will be provided, as part of their service agreement."  
    • Celine Lefebvre/Juliet Rubini: 24-0-0
    • Clarification
    • Non-substantive

    Description

      If the CDS Service will be sending information to a payer or outside entity (vs. an a CDS Service selected by practice to provide clinical recommendations), the physicians needs to know/approve this. It is concerning if merely opening a patient chart could trigger payer access to the EHR – particularly if a physician isn’t aware this is happening behind the scenes.

      Existing Wording:

      Often a prefetch template builds on the contextual data associated with the hook. For example, a particular CDS Service might recommend guidance based on a patient's conditions when the chart is opened.

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            celine_lefebvre Celine Lefebvre
            Celine Lefebvre
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              Updated:
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