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  1. FHIR Specification Feedback
  2. FHIR-36605

issue with framing of additional use cases section

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    • Icon: Change Request Change Request
    • Resolution: Not Persuasive with Modification
    • Icon: Highest Highest
    • US Da Vinci CRD (FHIR)
    • 1.1.0-ballot [deprecated]
    • Financial Mgmt
    • STU
    • Use Cases and Overview
    • 2.4
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      It's true that EHRs already provide decision support - but they can only provide decision support with respect to information they already know.  Payers may well be aware of information (e.g. based on submitted claims) that the EHR has no knowledge of.  As such, there's still value in providing this sort of decision support.

      That said, it would be worth being explicit that a payer should only provide decision support around contraindications, duplicate therapy, etc. if they know that they have information that is not already present in the EHR and where this information is not going to be provided from the payer via an alternative mechanism (e.g. NCPDP).  We should make that clear in the spec.  (Note that contraindications is not limited to drug-drug interactions - there are a wide variety of contraindication types that don't involve medications at all.)

       

      We will make explicit:

      • provision of decision support outside the coverage and documentation requirements space is optional (for both server and client)
      • servers that provide decision support for non-coverage/documentation areas SHALL check that the EHR does not have the information within its store that would allow it to detect the issue itself.  If the information already exists in the EHR, then the obligation is on the EHR to manage the issue detection and reporting in its own manner and payer systems should not get involved.
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      It's true that EHRs already provide decision support - but they can only provide decision support with respect to information they already know.  Payers may well be aware of information (e.g. based on submitted claims) that the EHR has no knowledge of.  As such, there's still value in providing this sort of decision support. That said, it would be worth being explicit that a payer should only provide decision support around contraindications, duplicate therapy, etc. if they know that they have information that is not already present in the EHR and where this information is not going to be provided from the payer via an alternative mechanism (e.g. NCPDP).  We should make that clear in the spec.  (Note that contraindications is not limited to drug-drug interactions - there are a wide variety of contraindication types that don't involve medications at all.)   We will make explicit: provision of decision support outside the coverage and documentation requirements space is optional (for both server and client) servers that provide decision support for non-coverage/documentation areas SHALL check that the EHR does not have the information within its store that would allow it to detect the issue itself.  If the information already exists in the EHR, then the obligation is on the EHR to manage the issue detection and reporting in its own manner and payer systems should not get involved.
    • Bob Dieterle / Jeff Brown : 22-0-1
    • Clarification
    • Compatible, substantive

    Description

      Regarding the following sentence – "Making providers aware of clinical risks (e.g. potential drug-drug interactions) based on payer knowledge from previous claims Improving accountable care delivery by making recommendations related to clinical practice guidelines or best practices"

      EHRs ALREADY have clinical alerts to ID drug interactions, provide recommendations and identify care gaps – if payers send this info too, it compounds existing alert fatigue.

      *We strongly urge payers to stick to proving COVERAGE information (not clinical suggestions, which is the physician's purview, and for which the physician already has EMR tech to assist with) in CRD. *

      Suggest adding some version of the aforementioned, and re-writing the sentence in a way that does not undermine that clinicians (as opposed to plans) are best situated to make recommendations about clinical matters.

      Also of note: the majority of drug/drug interactions are not going to be ID'd through the medical benefit – it would be the PBM and NCPDP standards. You may want to reconsider places in this guide where prescriptions are mentioned (such as in the examples used) that would not be covered by this Standard.

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