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?CSTABLE_HEAD_ACTORCSTABLE_HEAD_CATRule
 SHALL
 SHOULD
 MAY
 SHALL NOT
 SHOULD NOT
 Yes
 No
 Any
 PAS Client
 PAS Payer
 exchange
 privacy
 storage
§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.
§ainfo-2MAY PAS PayerexchangeA payer MAY request additional information from the provider to support a prior authorization request by responding to the X12 278 Request with an X12 278 Response
§ainfo-3SHALL PAS PayerexchangeWhen a single LOINC code is used, the TRN at the X12 278 header or line level associated with the 102089-0 LOINC code SHALL be the DTR context ID used to retrieve the appropriate questionnaire.
§ainfo-4SHALL PAS ClientexchangeThe PAS task profile SHALL be used to convey PAS X12 278 Response information to CDex.
§ainfo-5SHOULD PAS ClientexchangeAll of the additional information request codes SHOULD be used as input to a CDex task.
§ainfo-6SHALL PAS ClientexchangeWhen the LOINC code 102089-0 is present, the associated TRNs SHALL also be exchange as Task.input.
§ainfo-7SHALL PAS ClientexchangeA separate task SHALL be created for each of the above attachment request types (PWK01, LOINC, questionnaire).
§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.
§metric-1SHOULD
MAY
PAS Client
PAS Payer
storageEach of these IGs recommends a set of metrics that SHOULD or MAY be collected by their respective implementations to facilitate the evaluation of adoption, functionality, processes, and improved outcomes.
§metric-2SHOULD PAS Client
PAS Payer
storagePAS implementers SHOULD store information for each PAS call in a manner that would allow them to respond to measures based on this logical model.
§priv-1SHALL NOT
SHALL
PAS ClientprivacyImplementations SHALL permit provider review of data prior to transmission, but SHALL NOT require such review.
§priv-2SHOULD PAS PayerprivacyPayers who do not view the FHIR version of the transmitted information SHOULD be aware of the possibility of these limitations and ensure they have policies that enforce appropriate sharing constraints on data.
§priv-3SHOULD
MAY
PAS PayerprivacyPAS Servers SHOULD support server-server OAuth and MAY support mutually authenticated TLS.
§prof-1SHALL PAS ClientexchangeTimings SHALL have at least a count, frequency and period, a calendarPattern, or a deliveryPattern.
§prof-2SHALL PAS Client
PAS Payer
exchangeQuantities SHALL have a value and either a unit or a code
§prof-3SHALL PAS Client
PAS Payer
If a quantity code is present, it SHALL use the X12 quantity units.
§prof-4SHALL PAS ClientexchangeThe Claim instance of the update Bundle SHALL reference the updated Claim instance within the Claim.related.claim element. Note that the presence of this reference and the requirement that referenced instances be included in the submitted Bundle implies that the instance representing the prior version of the Claim SHALL be included in the update Bundle.
§prof-5SHALL PAS ClientexchangeThe Claim instance of the update Bundle SHALL contain within the Claim.item element each item requested in the updated claim and any prior versions of the claim, including requested items that have been added, modified, deleted, or left unchanged during this or previous updates.
§prof-6SHALL PAS ClientexchangeThe Claim instance of the update Bundle SHALL contain within the Claim.supportingInfo element each piece of supporting documentation submitted with the updated claim and any prior versions of claim, including supporting documentation that has been added, modified, deleted, or left unchanged during this or previous updates.
§prof-7SHALL PAS ClientexchangeEach Claim.item entry that represents an item no longer being requested, whether removed in this update or a previous one, SHALL be flagged using the infoCancelledFlag modifierExtension and SHALL have the code 3 (Cancel) in the Certification Type extension.
§prof-8SHALL PAS ClientexchangeEach Claim.supportingInfo entry that is no longer to be used when evaluating the request, whether removed in this update or a previous one, SHALL be flagged using the infoCancelledFlag modifierExtension.
§prof-9SHALL PAS ClientexchangeEach Claim.item and Claim.supportingInfo entry that has been changed as a part of this most recent update, including removal, SHALL be flagged using the changed extension with a value of changed.
§prof-10SHALL PAS ClientexchangeEach Claim.item and Claim.supportingInfo entry that has been added as a part of this most recent update, SHALL be flagged using the changed extension with a value of added.
§prof-ben-1SHALL X12 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 X12 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 All 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 A subscription-based mechanism SHALL be used by the client to be informed of updates to the authorization.
§spec-9SHOULD NOT 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 Provider 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 The Bundle SHALL be encoded in JSON.
§spec-12SHALL The 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 Additional 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 Each unique resource instance SHALL only appear at most once in the Bundle.
§spec-15SHOULD Only 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 Bundle.entry.fullUrl values SHALL be:
§spec-17SHALL All 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 Relevant resources referenced by those "supporting information" resources SHALL also be included (e.g. prescriber Practitioner and Medication for a MedicationRequest).
§spec-19SHALL Any such resource that has a US Core profile SHALL comply with the relevant US Core profiles.
§spec-20SHALL All "supporting information" resources included in the Bundle SHALL be pointed to by the Claim resource using the Claim.supportingInfo.valueReference element.
§spec-21SHOULD To attach non-FHIR instance data such as PDFs, CDAs, JPGs, a DocumentReference instance SHOULD be used.
§spec-22SHALL The Claim.supportingInfo.sequence for each entry SHALL be unique within the Claim.
§spec-23SHALL All resources SHALL comply with their respective profiles.
§spec-24SHOULD
MAY
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
Systems 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 In addition, the system SHALL make the entire PAS FHIR Bundle available to the intended payer.
§spec-27MAY The method MAY be based on the X12 275 or another method that trading partners have agreed to use.
§spec-28SHALL If 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 Translation/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 The Bundle SHALL start with a ClaimResponse entry that contains information mapped from the 278 response.
§spec-31SHALL Each unique resource instance SHALL only appear at most once in the Bundle.
§spec-32SHOULD Only 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 When 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 Each 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 In 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 For 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 The details of what was actually item SHALL be returned in the ClaimResponse.addItem.
§spec-38SHOULD 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 All transactions in PAS are synchronous and SHALL require one of the following HTTP responses:
§spec-40SHOULD If 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 NOTE: These errors SHOULD not be returned to the provider but SHOULD be reviewed and addressed by technical staff.
§spec-42SHOULD Although 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 Intermediaries SHALL interpret the 'not-applicable' code as no product or service code.
§spec-44SHALL This 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 The 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 the returned ClaimResponse SHALL include the current results for all submitted items, including any items changed or canceled since the original authoriation request.
§spec-47SHALL 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 I.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 systems 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 In 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 Implementers SHALL support subscriptions to provide the final response.
§spec-52SHALL Servers SHALL permit access to the prior authorization response to systems other than the original submitter.
§spec-53SHALL They 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 Implementers SHALL support the R4 Subscriptions referenced in the Subscriptions for R5 Backport Implementation Guide.
§spec-55SHALL Servers supporting subscriptions SHALL expose this as part of their CapabilityStatement
§spec-56SHALL Servers SHALL only support the rest-hook channel type
§spec-57SHALL This Subscription SHALL conform to the PAS Subscription profile.
§spec-58SHALL The Subscription filter criteria SHALL be org-identifier = [sending system identifier].
§spec-59SHALL Intermediaries SHALL ensure that subscriptions to monitor a particular sending system's prior authorizations are only created or modified by that sending system.
§spec-60SHALL Once 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 This notification SHALL include a full PAS Response Bundle.
§spec-62SHALL 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 When 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 Servers MAY reject updates and require that a new request is made by providing the appropriate X12 error code.
§spec-65SHALL The Claim that is being updated SHALL be referenced in the Claim.related.claim element and included in the Bundle.
§spec-66SHALL NOT If that Claim instance is itself a Claim Update, its referenced Claim SHALL NOT be included.
§spec-67SHALL All other referenced resources SHALL be included in the Bundle.
§spec-68SHALL When 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 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 Canceled items SHALL additionally contain a certificationType extension with a code of 3 (Cancel) in the Claim.item.extension element.
§spec-71SHALL 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 The 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 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.
§use-1SHALL PAS PayerexchangeThe intermediary SHALL always exchange a FHIR bundle with the EHR (figure 2.3)
§use-2SHALL PAS PayerexchangeThe intermediary SHALL convert the FHIR bundle to and from an X12 278 (and optionally to an X12 275) if necessary to meet the HIPAA transaction requirements
§use-3MAY PAS PayerexchangeThe intermediary MAY convert the X12 278 to and from a FHIR bundle and exchange it with a payer as long as the PA request and response are in an X12 278 format at some time between the exchange with the EHR and the payer
§use-4SHOULD PAS ClientexchangeAs well, EHRs SHOULD annotate their orders with the decisions contained in the PAS Response.
§use-5SHALL PAS ClientprivacyPrior to sending clinical data as part of the PAS exchange, the provider (or their designated agent) SHALL have the ability, but not an obligation, to review patient information and where appropriate amend or withhold the submission to comply with current regulations and relevant provider policies. The provider can choose to turn off the ability to review documentation. The vendor must allow them this option.
§use-6SHOULD PAS Client
PAS Payer
exchangeAll exchanges SHOULD meet Federal and state regulations, including any HIPAA restrictions and restrictions on sensitive data.