Da Vinci Prior Authorization Support (PAS) FHIR IG
2.2.0 - STU 2.2 United States of America flag

Da Vinci Prior Authorization Support (PAS) FHIR IG, published by HL7 International / Financial Management. This guide is not an authorized publication; it is the continuous build for version 2.2.0 built by the FHIR (HL7® FHIR® Standard) CI Build. This version is based on the current content of https://github.com/HL7/davinci-pas/ and changes regularly. See the Directory of published versions

Conformance Expectations

Page standards status: Trial-use

This page contains a table listing all the free-text conformance statements found in the IG. This table is provided as a useful summary for implementers for the purpose of evaluating key features and to support testing. However, reading this table alone is insufficient to understand or successfully implement the specification:

  1. The table only includes conformance expectations expressed as free text. It does not include the computable expectations represented in capability statements, profiles, value sets, etc.
  2. The text text in the table only includes the 'formal' requirement. It does not provide the contextual language around the statement that will be needed for successful explanation. The 'id' of each statement is a hyperlink to the place it appears in the text to assist with gathering the needed context.

A few other notes:

  • The ids are generally specific to the pages on which the requirements appear, but not always. If content is moved from one page to another, the id will remain the same.
  • While ids start as contiguous, as the specification is updated, it is possible some conformance statements will be removed, which will create a gap in the numbers. This is not an error.
  • Ids are not final until published in an official release. At that point, ids will not be changed.
  • It is possible for the text of a given rules to change somewhat from one release to another so long as the intention of the rule is the same. If the intent has a significant change, the old rule will be removed and a new one added in its place.
  • The actors are broken down into 'client' and 'server'. There may be multiple systems that actually compose those logical entities which will vary from implementation. It will be up to implementers to determine how the various conformance statements will apply to the actal systems in their architecture.
  • The categorizations are general. In practice, all 'exchange', 'ui', and 'storage' requirements are some aspect of 'processing' requirements. The categories will give hints as to the architectural layer a requirement will apply to, but there is nothing definitive implied by the category(ies) listed.

The controls at the top of the table allow filtering the content to particular requirement subsets that may be of interest.

IdExpectationConditional?ActorsRule
 SHALL
 SHOULD
 MAY
 SHALL NOT
 SHOULD NOT
 Yes
 No
 Any
 PAS Client
 PAS Payer
§1SHOULD ainfo-1^payer^exchange:Payers SHOULD attempt to use the initial DTR invocation to gather all relevant information relevant to the prior authorization request and only use the "additional information" approach when human review or other circumstances not known at the time of the initial DTR call require additional information to be collected.
§conf-1SHALL PAS PayerPayers SHALL have a distinct endpoint for each different supported version (which are not inter-version compatible) of the PAS specification.
§conf-2SHALL PAS PayerIf a payer supports endpoint discovery, they SHALL have at most a single endpoint for each combination of version of the specification and coverage (e.g., Medicare, Medicaid, or commercial) they provide coverage under.
§conf-3SHALL PAS PayerIf a payer does not support endpoint discovery, they SHALL expose only one PAS endpoint of each supported version capable of handling all coverages.
§conf-4SHALL PAS PayerPA Intermediary Systems SHALL be capable of processing all data elements that are marked as Must Support on the Claim Request and Claim Inquiry.
§conf-5SHALL NOT PAS PayerThey SHALL NOT generate an error or cause the application to fail due the presence of any data element marked as Must Support.
§conf-6SHALL PAS PayerPA Intermediary Systems SHALL be capable of returning resource instances containing any of the data elements that are marked as Must Support on the Claim Response and the Claim Inquiry Response.
§conf-7SHALL PAS ClientPA Client Systems SHALL be capable of receiving all data elements that are marked as Must Support on the Claim Response and the Claim Inquiry Response.
§conf-8SHALL NOT PAS ClientThey SHALL NOT generate an error or cause the application to fail when receiving any data element that is marked as Must Support.
§conf-9SHOULD NOT PAS ClientPA Client Systems SHOULD NOT send any data elements that are not marked as Must Support.
§conf-10MAY PAS PayerIf these data elements are included in a Claim Request or Claim Inquiry, the receiving PA Intermediary System MAY ignore those elements.
§conf-11SHALL NOT PAS PayerWhen processing prior auth requests and additional data submissions, PAS services SHALL NOT depend on or set expectations for the inclusion of resource instances not compliant with profiles defined in this guide, CRD, DTR, HRex, or US Core.
§conf-12SHALL NOT PAS PayerSimilarly, they SHALL NOT depend on or set expectations for the inclusion of any data elements not marked as mandatory (min cardinality >= 1) or mustSupport in those profiles.
§conf-13MAY PAS Client
PAS Payer
If the proposed change is adopted and published in the PAS continuous integration build or the CI build of one of its dependencies (e.g. US Core), implementations MAY, by mutual agreement, pre-adopt the use of those additional profiles and/or mustSupport data elements and not be considered in violation of #1 above.
§conf-14SHALL NOT PAS Client
PAS Payer
Where cardinality and other constraints present in profiles allow data elements to be omitted, PAS compliant systems SHALL NOT treat the omission of those elements as a conformance error.
§conf-15SHALL PAS Client
PAS Payer
PAS clients and services SHALL use standard PAS data elements (i.e. elements found within PAS-defined or inherited profiles and marked as mandatory or mustSupport) to communicate needed data if such elements are intended to convey such information.
§conf-16SHALL NOT
MAY
PAS Client
PAS Payer
PAS implementing organizations SHALL NOT publish guidance setting expectations for where certain data elements are conveyed within PAS and inherited data structures, but MAY submit change requests to PAS, HRex, or US Core requesting that additional guidance be provided to implementers on data structure usage to increase consistency across implementations.
§prof-3SHALL PAS Client
PAS Payer
If a quantity code is present, it SHALL use the X12 quantity units.
§prof-ben-1SHALL PAS PayerX12 standard requires no dash for ZIP+4 codes and that intermediaries SHALL expect the dash to be present and SHALL remove the dash, if present, when converting the zip code to meet the X12 standard.
§prof-sub-1SHALL PAS PayerX12 standard requires no dash for ZIP+4 codes and that intermediaries SHALL expect the dash to be present and SHALL remove the dash, if present, when converting the zip code to meet the X12 standard.
§spec-1SHALLXPAS Client
PAS Payer
Along with the profiles defined in the PAS implementation guide, implementations SHALL also support the relevant US Core profiles for supplementary information.
§spec-2SHOULDXPAS Client
PAS Payer
They SHOULD support any other profiles relevant to the types of prior authorizations they process.
§spec-3SHOULDXPAS Client
PAS Payer
Clients and Servers supporting this implementation guide SHOULD also comply with the Da Vinci Coverage Requirements Discovery (CRD) and Documentation Templates and Rules (DTR) implementation guides.
§spec-4SHALLXPAS Client
PAS Payer
Every system claiming conformance to this IG SHALL comply with the Security and Privacy page in the Da Vinci HRex guide.
§spec-5SHALLXPAS PayerIf a payer supports endpoint discovery, they SHALL have at most a single endpoint for each coverage (e.g., Medicare, Medicaid, or commercial) they provide coverage under.
§spec-6SHALLXPAS PayerIf a payer does not support endpoint discovery, they SHALL expose only one PAS endpoint capable of handling all coverages.
§spec-7SHOULD PAS PayerAll of this SHOULD happen synchronously with a maximum of 15 seconds between the user initiating the prior authorization request and seeing the resulting response - i.e. including network transmission time for request and response.
§spec-8SHALL PAS ClientA subscription-based mechanism SHALL be used by the client to be informed of updates to the authorization.
§spec-9SHOULD NOT PAS Payer
PAS Client
NOTE: The Claim Inquiry response does not include all of the information that can be returned in a request response, such as any request for additional information, so the inquire operation SHOULD NOT be used by the client while waiting for final results.
§spec-10MAY PAS PayerProvider and EHR Vendor organizations MAY leverage the payer registry developed by PDex (which will eventually fold into the national directory under FAST) as a means of determining which endpoints exist for which payers as candidates for configuration.
§spec-11SHALL PAS PayerThe Bundle SHALL be encoded in JSON.
§spec-12SHALL PAS PayerThe first entry in the Bundle SHALL be a Claim resource complying with the profile defined in this IG to ensure the content is sufficient to appropriately populate an X12N/005010X217 message.
§spec-13SHALL PAS PayerAdditional Bundle entries SHALL be populated with any resources referenced by the Claim resource (and any resources referenced by those resources, fully traversing all references and complying with all identified profiles).
§spec-14SHALL PAS PayerEach unique resource instance SHALL only appear at most once in the Bundle.
§spec-15SHOULD PAS PayerOnly one unique resource instance SHOULD be created to represent the same information. In other words, avoid creating multiple Practitioner instances for the same person.
§spec-16SHALL PAS PayerBundle.entry.fullUrl values SHALL be:
§spec-17SHALL PAS PayerAll GUIDs used SHALL be unique, including across independent prior authorization submissions - with the exception that the same resource instance being referenced in distinct prior authorization request Bundles can have the same GUID.
§spec-18SHALL PAS PayerRelevant resources referenced by those "supporting information" resources SHALL also be included (e.g. prescriber Practitioner and Medication for a MedicationRequest).
§spec-19SHALL PAS PayerAny such resource that has a US Core profile SHALL comply with the relevant US Core profiles.
§spec-20SHALL PAS PayerAll "supporting information" resources included in the Bundle SHALL be pointed to by the Claim resource using the Claim.supportingInfo.valueReference element.
§spec-21SHOULD PAS PayerTo attach non-FHIR instance data such as PDFs, CDAs, JPGs, a DocumentReference instance SHOULD be used.
§spec-22SHALL PAS PayerThe Claim.supportingInfo.sequence for each entry SHALL be unique within the Claim.
§spec-23SHALL PAS PayerAll resources SHALL comply with their respective profiles.
§spec-24SHOULD
MAY
PAS Client
PAS Payer
FHIR elements not marked as 'must support' MAY be included in resources within the Bundle, but client systems SHOULD have no expectation of such elements being processed by the payer unless prior arrangements have been made.
§spec-25SHALL
MAY
PAS PayerSystems that do not process such elements SHALL ignore unsupported elements unless they are 'modifier' elements, in which case the system MAY treat the presence of the element as an error.
§spec-26SHALL PAS Client
PAS Payer
In addition, the system SHALL make the entire PAS FHIR Bundle available to the intended payer.
§spec-27MAY PAS PayerThe method MAY be based on the X12 275 or another method that trading partners have agreed to use.
§spec-28SHALL PAS PayerIf the X12 275 is used for this purpose, the 275 BDS01 Filter ID Code element SHALL be set to "B64" and the CAT02 Attachment Information Format Code element SHALL be sent to "HL".
§spec-29SHOULD PAS PayerTranslation/mapping systems SHOULD be aware that if the size of the attachments as part of a claims submission would exceed the size limitations of a particular recipient, the intermediary SHOULD split the attachments into separate 275s to remain within the overall limit.
§spec-30SHALL PAS PayerThe Bundle SHALL start with a ClaimResponse entry that contains information mapped from the 278 response.
§spec-31SHALL PAS PayerEach unique resource instance SHALL only appear at most once in the Bundle.
§spec-32SHOULD PAS PayerOnly one unique resource instance SHOULD be created to represent the same information. In other words, avoid creating multiple Practitioner instances for the same person.
§spec-33SHALL PAS PayerWhen echoing back resources that are the same as were present in the prior authorization request, the system SHALL ensure that the same fullUrl and resource identifiers are used in the response as appeared in the request.
§spec-34SHALL PAS PayerEach item returned on the PAS ClaimResponse SHALL echo the same item.sequence as that same item had on the Claim. The item.sequence element SHALL serve as the main tracing identifier of items throughout requests and responses.
§spec-35SHALL PAS ClientIn the case of an error in an Operation invocation (e.g., 4XX error), the receiving system SHALL return a single OperationOutcome that details why the Bundle could not be processed.
§spec-36SHALL PAS PayerFor instances where the authorized item is a modification of the requested item, the requested item details SHALL be returned in the ClaimResponse.item with an adjudication status of A6 - 'Modified'.
§spec-37SHALL PAS PayerThe details of what was actually item SHALL be returned in the ClaimResponse.addItem.
§spec-38SHOULD PAS Client
PAS Payer
Recipients of the transactions SHOULD respond as indicated below and senders of the transaction SHOULD look for the following responses and then take appropriate actions.
§spec-39SHALL PAS PayerAll transactions in PAS are synchronous and SHALL require one of the following HTTP responses:
§spec-40SHOULD PAS ClientIf an OperationOutcome is received, it may have information regarding errors that SHOULD be addressed in the future, but did not cause the transaction to fail.
§spec-41SHOULD PAS PayerNOTE: These errors SHOULD not be returned to the provider but SHOULD be reviewed and addressed by technical staff.
§spec-42SHOULD PAS ClientAlthough there are no constraints on the frequency of the query, clients SHOULD ensure that no repetitive inquiries do not happen so as not to stress payer systems.
§spec-43SHALL PAS PayerIntermediaries SHALL interpret the 'not-applicable' code as no product or service code.
§spec-44SHALL PAS PayerThis Claim Inquiry Response SHALL either reference a Claim or have a Data Absent Reason indicating why the Claim can not be referenced (eg. original claim received by fax).
§spec-45SHOULD PAS PayerThe referenced Claim instance SHOULD be returned if there is information in the Response that needs to be present can not be returned in the Claim Response instance.
§spec-46SHALL PAS Payerthe returned ClaimResponse SHALL include the current results for all submitted items, including any items changed or canceled since the original authoriation request.
§spec-47SHALL PAS Client
PAS Payer
if a specific reference number (either the REF-NT or REF-BB) is submitted and is not the 'current' number (because subsequent additions/changes/cancellations have been made to the prior authorization request), the returned record SHALL be the current authorization response - even though it no longer has the same identifier.
§spec-48SHALL PAS PayerI.e. If a search is for a 'replaced' prior authorization, the search result SHALL include the 'current' prior authorization response for the most recent replacing prior authorization request.
§spec-49MAY PAS Payersystems MAY withhold information about prior authorizations that are 'open' but are deemed to be not relevant to the provider (eg. prior authorization requests for sensitive care where the requesting provider is neither the ordering nor rendering provider) who is checking for the prior authorization status if not searching by a specific Claim identifier.
§spec-50SHOULD PAS PayerIn such situations the response SHOULD include an OperationOutcome warning that some prior authorizations have been suppressed and provide an alternative mechanism (e.g. telephone number) to provide further information if needed.
§spec-51SHALL PAS PayerImplementers SHALL support subscriptions to provide the final response.
§spec-52SHALL ^payerServers SHALL permit access to the prior authorization response to systems other than the original submitter.
§spec-53SHALL PAS PayerThey SHALL require a match on the patient member or subscriber id (identifier on the Claim.patient) plus the ordering and/or rendering provider identifier, i.e. the provider's NPI.
§spec-54SHALL PAS PayerImplementers SHALL support the R4 Subscriptions referenced in the Subscriptions for R5 Backport Implementation Guide.
§spec-55SHALL PAS PayerServers supporting subscriptions SHALL expose this as part of their CapabilityStatement
§spec-56SHALL PAS PayerServers SHALL only support the rest-hook channel type
§spec-57SHALL PAS PayerThis Subscription SHALL conform to the PAS Subscription profile.
§spec-58SHALL PAS PayerThe Subscription filter criteria SHALL be org-identifier = [sending system identifier].
§spec-59SHALL PAS PayerIntermediaries SHALL ensure that subscriptions to monitor a particular sending system's prior authorizations are only created or modified by that sending system.
§spec-60SHALL PAS PayerOnce the subscription has been created, the Server SHALL send a notification over the requested channel indicating that a prior authorization response submitted by the requesting provider organization has changed.
§spec-61SHALL PAS PayerThis notification SHALL include a full PAS Response Bundle.
§spec-62SHALL PAS Client
PAS Payer
Due to the inquiry not supporting all of the required information needed in a PAS response, PAS Clients and Intermediaries SHALL only support subscriptions with content='full-resource'.
§spec-63SHOULD PAS ClientWhen details of a submitted request change and a provider needs to request prior authorization of a different set of items, clients SHOULD submit an update to the previously submitted Claim.
§spec-64MAY PAS Client
PAS Payer
Servers MAY reject updates and require that a new request is made by providing the appropriate X12 error code.
§spec-65SHALL PAS PayerThe Claim that is being updated SHALL be referenced in the Claim.related.claim element and included in the Bundle.
§spec-66SHALL NOT PAS PayerIf that Claim instance is itself a Claim Update, its referenced Claim SHALL NOT be included.
§spec-67SHALL PAS PayerAll other referenced resources SHALL be included in the Bundle.
§spec-68SHALL PAS ClientWhen changing the details of the request, the Claim instance SHALL contain all item and supportingInfo entries from the original Claim and any previous update Claims with sequence values preserved, but with the current request details.
§spec-69SHALL PAS Client
PAS Payer
Cancelled entries: item and supportingInfo entries that have been removed from the request SHALL include the infoCancelled modifier extension with a valueBoolean of true in the Claim.item.modifierExtension or Claim.supportingInfo.modifierExtension element.
§spec-70SHALL PAS Client
PAS Payer
Canceled items SHALL additionally contain a certificationType extension with a code of 3 (Cancel) in the Claim.item.extension element.
§spec-71SHALL PAS Client
PAS Payer
Entries added, modified, or cancelled compared to the immediately prior version of the Claim referenced in the Claim.related.claim element SHALL contain a infoChanged extension within the Claim.item or the Claim.supportingInfo element.
§spec-72SHALL PAS PayerThe infoChanged extension for added entries SHALL have a valueCode of changed and those for modified or deleted entries SHALL have a valueCode of changed (newly marking an item as canceled is considered a 'change').
§spec-73SHALL PAS PayerPAS systems SHALL ensure that prior authorizations that were initially pended remain available for query for at least 6 months after the anticipated completion of the services whose authorization was requested.