Section 3.1.1, Da Vinci Burden Reduction, states that "DTR might be invoked directly by a clinician who either knows or is informed by means other than CRD about the requirement to gather additional documentation", but later sections do not support this ability and do not describe a way to retrieve a payer questionnaire outside of CRD. The "Use of Card.links",  "Retrieval of Payer Resources", "Usage Sessions", and "Launch outside of CRD" sections, in particular, state that when launched outside of the CRD context, the DTR app should only restore an existing session, not begin a new DTR process.

This implementation guide should include details as to how a DTR application launched outside of CRD could query a predefined payer endpoint with the appropriate Order and Coverage resources in order to retrieve the payer's Questionnaire and CQL rules and perform the DTR process. We should also clarify that this non-CRD initial launch of the DTR application could either be initiated manually by a user or automatically by the EHR.

A specific use case for this is when the ordering provider system is distinct from the performing provider system, and the performing provider has the responsibility to obtain prior authorization. While the ordering provider could trigger CRD and DTR, create a Task and a QuestionnaireResponse, and then share these resources with the performing provider, this isn't something we should necessarily expect any two provider systems to be able to do.