"There is no need for the user to see the Questionnaire if it can be auto completed, unless they need to approve sending the result to the payer or to sign the information prior to submission. The application SHALL give the provider the ability, but not the requirement to review any information prior to sending it to a third party. This ability may be turned-off by the organization and possibly the individual provider."

This is awkwardly worded, and unclear how this will work from a technical perspective.  Data gets auto-populated by the CQL logic when the form is being rendered (for a user).  Form fillers don't typically populate data without it being exposed to a user.  Also, there are times where populated data requires validation and times where perhaps it might not.  However, there's no computable way to differentiate between these circumstances.

Further, sending information to a third party isn't something that falls in the scope of DTR.  The resulting QR is stored in the EHR.  Sending it to a payer or elsewhere is part of the prior auth or claims submission process.

Finally, what is the computable manner in which an EHR launching a SMART app can 'turn off' the ability to review the data when the SMART app is launched?  (Whether it does this for all users or only some really doesn't matter to the DTR spec.)

Suggest rewording to say "DTR will automatically populate the answers to certain questions based on existing EHR data.  In some cases, it may populate all answers to the Questionnaire.  It is up to organizations to set expectations for providers as to the degree review users should apply to pre-populated answers prior to saving the resulting response for subsequent use within the EHR."  (And of course moving this to a page that actually deals with the pre-population process.)