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  1. FHIR Specification Feedback
  2. FHIR-35789

Requirement for deidentified CRD

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    • Icon: Change Request Change Request
    • Resolution: Not Persuasive with Modification
    • Icon: Medium Medium
    • US Da Vinci CRD (FHIR)
    • current
    • Clinical Decision Support
    • Supported Hooks
    • 4.2.1
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      De-identified invocation is a hard requirement from CMS - and CMS is one of the most critical payers.  They will NOT allow the receipt of identifiable patient information over this interface.  We don't believe this specification can be productively implemented without this requirement.

      We will add a "note to balloters" indicating that there is controversy around this requirement being mandatory and we are seeking feedback from industry around the implications of the "no-PHI" aspect being mandatory.

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      De-identified invocation is a hard requirement from CMS - and CMS is one of the most critical payers.  They will NOT allow the receipt of identifiable patient information over this interface.  We don't believe this specification can be productively implemented without this requirement. We will add a "note to balloters" indicating that there is controversy around this requirement being mandatory and we are seeking feedback from industry around the implications of the "no-PHI" aspect being mandatory.
    • Bob Dieterle / Celine Lefebvre: 19-0-3
    • Clarification
    • Non-substantive

    Description

      Existing wording:

      Therefore, CRD Clients SHALL provide support for Coverage Requirements Discovery without PHI using a redacted view where the resources exposed through the CDS Hooks and SMART on FHIR interfaces are filtered as follows:

      AND

      CRD Clients SHALL determine whether a CRD Service will use the PHI or non-PHI version of the CRD interface at the time the CRD Service is configured to have access to their system. In situations where PHI will never be required to perform Coverage Requirements Discovery, the redacted view SHALL be used. 

       

      Issue:

      Not all FHIR implementations have the capabilities to de-identify and strip out potential PHI as described. Therefore use of SHALL here is very prescriptive and unreasonable. Request to change it to MAY or SHOULD.

       

      Proposed wording:

      Therefore, CRD Clients MAY provide support for Coverage Requirements Discovery without PHI using a redacted view where the resources exposed through the CDS Hooks and SMART on FHIR interfaces are filtered as follows:

       AND

      CRD Clients SHOULD determine whether a CRD Service will use the PHI or non-PHI version of the CRD interface at the time the CRD Service is configured to have access to their system. In situations where PHI will never be required to perform Coverage Requirements Discovery, the redacted view MAY be used.

       

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            Unassigned Unassigned
            m_varghese Varghese Mathew
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              Updated:
              Resolved: