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  1. FHIR Specification Feedback
  2. FHIR-30816

Please clarify whether any human involvement is required, and an example, as well as define the term fulfillment as it relates to attestation.

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    • Icon: Change Request Change Request
    • Resolution: Persuasive with Modification
    • Icon: Highest Highest
    • US Da Vinci CDex (FHIR)
    • current
    • Patient Care
    • Specification [deprecated]
    • 8.1
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      Clarifications included as part of FHIR-26855 which defines how to request signatures and what the signature means for 

      Data Query:  

      • The signature SHALL represent a system-level attestation by the sending organization that they are the source of the information.

      Task Based Requests and new draft Push mechanism section(see FHIR-33139)

      • The signature SHALL represent a human provider signature on resources attesting that the information is true and accurate.

      RE the commenter concern: We would be concerned if the required signature means that the physician must select a null flavor if there isn't information to meet the data request.

      This situation there isn't information to meet the data request would result in: 

      • Data Query:  empty signed searchset bundle
      • Task Based Requests: If there no data to return, the task cannot be completed ( ~/Davinci-CDEX/output/specification.html#when-the-task-cannot-be-completed). There is no signature requirement in this case.  If the data is partially completed then only the available  signed data is returned.
      • New draft Push mechanism section(see FHIR-33139): no information would not be sent

      RE the comment: "We are also not clear on what attesting to “fulfillment” means – does this mean the information was provided? Wouldn’t the payer receiving the information suffice – why is attestation needed"

      This is a business requirement. some data consumers may require that the data they receive are signed. For example, the CMS Attachments Rules.

       

           

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      Clarifications included as part of FHIR-26855 which defines how to request signatures and what the signature means for  Data Query:   The signature  SHALL  represent a  system-level  attestation by the sending organization that they are the source of the information. Task Based Requests and new draft Push mechanism section(see FHIR-33139 ) The signature  SHALL  represent a  human provider  signature on resources attesting that the information is true and accurate. RE the commenter concern:  We would be concerned if the required signature means that the physician must select a null flavor if there isn't information to meet the data request. This situation there isn't information to meet the data request would result in:  Data Query:  empty signed searchset bundle Task Based Requests: If there no data to return, the task cannot be completed ( ~/Davinci-CDEX/output/specification.html#when-the-task-cannot-be-completed). There is no signature requirement in this case.  If the data is partially completed then only the available  signed data is returned. New draft Push mechanism section(see FHIR-33139 ): no information would not be sent RE the comment: "We are also not clear on what attesting to “fulfillment” means – does this mean the information was provided? Wouldn’t the payer receiving the information suffice – why is attestation needed" This is a business requirement. some data consumers may require that the data they receive are signed. For example, the CMS Attachments Rules.        
    • Eric Haas/Jay Lyle: 8-0-1
    • Clarification
    • Compatible, substantive

    Description

      We would be concerned if the required signature means that the physician must select a null flavor if there isn't information to meet the data request. Would be valuable to see an example or use case where the EHR makes the attestation and how, if any, human involvement is required, as it is unclear if “EHR attesting” means a person needs to be involved. We are also not clear on what attesting to “fulfillment” means – does this mean the information was provided? Wouldn’t the payer receiving the information suffice – why is attestation needed?

      Existing Wording:

      Depending on the reason for the request, Payers may require signatures from EHRs attesting to the fulfillment of the data request. However, there has not been enough implementation experience with this to provide specific guidance on how this is done. We are seeking implementer feedback and comments on this issue

      (Comment 6 - imported by: Jean Duteau)

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            celine_lefebvre Celine Lefebvre
            Celine Lefebvre
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