CRD specification is doing all it can to make the ordering provider be the person getting the authorization, or at least getting the process started. This is good. 

However, let's say, the ordering sees that prior auth is required (either in the CRD response or some other way - side note here that I agree with JIRA 36129), and starts DTR. Let's also assume an unusually gracious provider who actually completes the DTR all by themselves, without to support staff. (Or even if it is pended to support staff, and they complete it, the problem below would still stand?)

Now, DTR is complete, and it is sitting there. Patient goes to a different organization which is the performing organization. 

DTR/PAS specs do not account for how this questionnaire response that is sitting at the ordering provider organization gets handed off to the performing provider organization. So now, the performing provider organization will essentially start from scratch. But since they don't have all the info, they will have to phone the ordering provider, who will have to fax them the responses. 

Therefore, I think DTR MUST specify a mechanism by which the QuestionnaireResponse can flow from the ordering provider organization to the performing provider organization in cases where PAS is done by the performing provider organization. 

Also, a variant of this is where some information in DTR is available to the ordering provider, and some to the performing provider. In this case, there needs to be a process by which DTR can be passed back and forth across organizations, Going across organizations means different FHIR ISS, different IDs etc. So this is a complex problem, but afaik still needs some form of solution.