Da Vinci Payer Data Exchange
2.1.1 - STU2 Ballot
Da Vinci Payer Data Exchange
2.1.1 - STU2 Ballot
Da Vinci Payer Data Exchange, published by HL7 International / Financial Management. This guide is not an authorized publication; it is the continuous build for version 2.1.1 built by the FHIR (HL7® FHIR® Standard) CI Build. This version is based on the current content of https://github.com/HL7/davinci-epdx/ and changes regularly. See the Directory of published versions
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In December 2022, CMS released the Advancing Interoperability and Improving Prior Authorization Processes Proposed Rule CMS-0057-P.
This rule was finalized in February 2024.
One of the requirements of the rule is for Impacted Payers to implement a Provider Access API.
This is an API that conforms to the HL7 FHIR Bulk Data API specification.
The purpose of the Provider Access API is to enable Providers to query a Payer API for information
about the members of the health plan where they have a current, or upcoming treatment relationship.
The API will enable a provider to ask a Payer "What do you know about my Patients?"
The Payer Data Exchange Implementation Guide supports the Provider Access API by utilizing the $Davinci-data-export-operation operation in the Da Vinci Member Attribution Implementation Guide.
This IG is not overly prescriptive in how to construct and manage Member Attribution lists. Health plans are responsible for managing Member Attribution Lists according to their own business rules for determining whether a Provider and Member have an existing, or impending treatment relationship.
This IG recognizes that the healthcare industry is rapidly evolving methods, such as TEFCA, to enable the secure exchange of information between Providers and Payers. Incorporating prescriptive definitions for connecting, registering and authorizing access to the Provider Access API risks complicating the adoption of solutions that will enable secure exchange of data, at scale.
The diagram below illustrates how health plans may construct and maintain their Member Attribution lists for Organizations, Locations and Providers. It also illustrates how a Provider Representative, such as an EMR, can query the health plan for the PDexProviderGroup resources they are permitted to see and then use the Group/{id} endpoint for those records to request Member clinical, prior authorization and non-financial claims and encounter data.
The typical use case is expected to be one where an EMR retrieves data from a health plan for one or more providers using automated service functions. The retrieving system or service, such as an EMR, is presumed to have implemented Role-based access to ensure that only authenticated and authorized personnel, or systems, have access to the retrieved data.
It is recommended that, at a minimum, health plans create Member Attribution Lists using the NPI data for the Rendering Provider. Health plans MAY choose to construct alternative or additional Attribution Lists that cover more than one provider, for example by creating an Attribution list for all providers at a specific facility.
A health plan member is entitled to opt-out of data sharing via the Provider Access API. PDex defines a consent profile that enables a member to deny sharing via the Provider Access API. A member should also be able to update their preference to revoke a previous denial.
Health Plans SHALL implement the pdex-provider-consent to enable a member to express their sharing preference.
The PDex Server Capability Statement enables the Consent record to be written to the Patient Access API.
See the PDex Provider Consent here
The Provider Access API is centered around Attribution lists that enable a Provider/Provider Organization or Facility to retrieve data for health plan members that are assigned to that Provider. The data retrieval uses a FHIR Bulk data export operation to retrieve the requested data.
Members SHALL have the ability to opt-out of data sharing with providers.
The Health Plan is responsible for managing Attribution Lists. Attribution Lists SHOULD be discrete lists at the Organization + Facility + Provider level. This level of granularity is needed to account for Providers working across different organizations, or at different facilities that may use different EMRs. A health plan MAY adopt their own methodology for managing and maintaining provider attribution lists. Health plans are encouraged, for transparency purposes, to share their methodology for managing Member Attribution.
Health plans:
Attribution lists SHALL be searchable via a secure RESTful API. Access to the Group resource to READ attribution lists should be scoped to the appropriate Organization, Facility, Provider or their authorized representative that is acting on the behalf of the Provider.
The Da Vinci Data Export Operation in the Member Attribution IG supports the Bulk FHIR API specification. The operation uses the Group resource. For the PDex Provider Access API the following capabilities SHOULD be supported:
This combination of requests should cover all provider data requests, such as:
Access SHALL be controlled using client credentials that are compliant with SMART-On-FHIR. Access SHOULD be restricted to Providers with a contractual relationship with a Payer.
The $davinci-data-export operations SHALL be submitted using a HTTP POST. The HTTP Header SHALL include:
Prefer: respond-async
The Payer SHALL be responsible for managing and maintaining the attribution list that assigns Members to Providers. The payer SHALL take account of members that have chosen to Opt-out of sharing data with providers. Those opted-out members SHALL be omitted from the Provider Attribution list. The Payer MAY choose to maintain a separate Group resource for a Provider that identities the Opted-out Members that would otherwise have been Attributed to the Provider. If a Payer maintains an Opted-out Group resource it is the Payers responsibility to ensure that a Provider is unable to download data about those opted-out members using a bulk export operation. The Da Vinci Member Attribution (ATR) IG provides transactions to manage the Group resource through Add, change and delete member actions.
The AttributionListStatus extension can have one of three values:
A provider MAY have more than one list. For example, a list marked as Final related to a Value-based care contract and an "open" list where the Provider is still accepting patients under a different care arrangement.
The PDexProviderGroup profile SHALL be used to record the members attributed to a Provider, Provider Group or Organization. PDexProviderGroup is based on the ATRGroup Profile from the Da Vinci Member Attribution (ATR) 2.0.0 IG.
The profile adds an extension at the root level. This is used to, optionally, record the number of potentially attributed members that instead used their right to opt-out of sharing data with providers. By recording this quantity it MAY help providers reconcile their attribution lists with those managed by the Payer, The extension is:
The PDexProviderGroup Profile adds three extensions to the member element. These are used to track the data retrieved for a member by the provider. This enables sophisticated providers to fine tune their requests for data. For example, Retrieving the group resource a Provider could create a Provider Access data request that repeated the parameters supplied to lastResources and lastFilters and compile a list of Patients with the same lastTransmitted date. The Provider Access API is flexible enough that a Provider could submit a request for the data for a single Patient, repeating the previously used parameters. A Provider could also compile a request that omitted resources that were previously asked for, avoiding data duplication. Providing these member-level extensions is meant as an aid to Providers and Payers to enable granular data sharing. Providers, or Payers wishing to take advantage of these elements SHOULD consider implementing their own independent data tracking capabilities to understand what data has been provided to a Provider for specific members.
The member-level extensions are primarily intended for instances where a Provider does not want to download ALL information for ALL attributed members.
The member-level extensions are:
These extensions SHALL be updated by the $davinci-data-export PDex Use Case Operation.
A Provider Representative may need to manage multiple attribution lists. The FHIR Group resource supports searching on characteristic. To enable searching the PDexMemberMatchGroup Profile sets the characteristic element to include the "pdexprovidergroup" code, the identifier of the provider in (characteristic.valueReference), sets characteristic.exclude to false and characteristic.period.start to the date attribution list creation or update.
Implementers SHALL support the standard search parameters for group that are specified in the base Group resource in FHIR R4 specification: Group Search Parameters.
The Provider Access is meant to enable in-network providers to retrieve the information they want about one or more patients that are attributed to them via an existing , or impending treatment relationship. Under the requirements of the CMS Prior Authorization Rule (CMS-0057) the data available through the API SHOULD include:
The CMS Prior Authorization Rule (CMS-0057) requires Claims and Encounter data to be exchanged with Providers and Payers via the respective Provider Access API and Payer-to-Payer APIs, defined in this IG. The Rule requires that a non-financial view of those claims and encounters are provided. This IG utilizes the work of the CARIN Consumer Directed Payer Data Exchange IG which defines the following non-financial profiles:
Provider Representative:
The $davinci-data-export operation enables a Provider Representative to perform granular requests for data.
Data can be constrained by:
Data available via the API includes:
The Data Export operation SHALL check the consent status for each member at the time of execution. This is necessary to identify members that may have changed their opt-out status for sharing with providers.
If the patient parameter is not provided data SHALL be retrieved for all members in the Group. If the patient parameter is provided the operation SHALL ignore references to patients that are invalid, or not a member of the group.
This is an optional parameter in the Da Vinci Data Export Operation. The exportType parameter SHALL have one of the following values:
The hl7.fhir.us.davinci-pdex#provider-delta option SHALL be used when the provider is retrieving new, or updated data that will be stored as part of the patient record.
The hl7.fhir.us.davinci-pdex#provider-download option SHALL be used when the provider is retrieving data that will be stored as part of the patient record.
The hl7.fhir.us.davinci-pdex#provider-snapshot value SHOULD be used when a provider wants to download data for viewing.
From the Data Provider's perspective the hl7.fhir.us.davinci-pdex#provider-download exportType parameter will require the Data Provider/Payer to track the latest download date/time for the Patients that the provider requests data for. These values SHALL be updated in an extension associated with the Patient for which a download was requested.
Resources in the Patient Access and Provider Access API can extend back to January 1, 2016. The _since parameter SHOULD be used for resource requests when the full history is not required. It is expected that providers MAY first request data for members without limiting the request using the _since parameter. Subsequent requests MAY then use _since to limit data to information that is new.
The _until parameter MAY be used less frequently. It is most likely to be used with the
hl7.fhir.us.davinci-pdex#provider-snapshot exportType to retrieve member data for a specific
period.
The _type parameter MAY be used to restrict the resources retrieved by the Provider. This enables providers to only retrieve the resource types they are interested in seeing. If this parameter is not used all available resources SHALL be returned by the Payer, subject to the constraints applied by other input parameters.
When _type is used the export operation SHALL record the content of the _type parameter in the lastResources element for each Member for which data is retrieved. The lastTransmitted SHALL be recorded with either the Date/Time of the Export Transaction or the value of the _until parameter, if it is earlier.
The _typeFilter parameter MAY be used to further restrict the resources retrieved by the Provider. For example, to only retrieve Observations of a certain type. The _typeFilter, if used, SHALL comprise one, or more, valid FHIR search queries for the respective resource being filtered.
When _typeFilter is used the export operation SHALL record the content of the _typeFilter parameter in the lastFilters element for each Member for which data is retrieved. The lastTransmitted SHALL be recorded with either the Date/Time of the Export Transaction or the value of the _until parameter, if it is earlier.
NOTE: When constructing search queries to incorporate into a _typeFilter, Search parameters supported by the relevant profiles from the PDex, US Core or CARIN Blue Button IGs SHALL be followed.
Implementers SHOULD implement OAuth 2.0 access management in accordance with the SMART Backend Services Authorization Profile. When SMART Backend Services Authorization is used, Bulk Data Status Request and Bulk Data Output File Requests with requiresAccessToken=true SHALL be protected the same way the Bulk Data Kick-off Request, including an access token with scopes that cover all resources being exported. A server MAY additionally restrict Bulk Data Status Request and Bulk Data Output File Requests by limiting them to the client that originated the export. Health plans SHALL limit the data returned to only those FHIR resources for which the client is authorized.
Clients SHALL require OAuth client credentials to enable secure access to read and search the Group resources and perform Bulk export operations. Access Tokens SHALL be required to access the Group resources and and the Bulk export operation. Access and Refresh Tokens SHOULD be issued to support the client requesting and subsequently retrieving the bulk data response to their request.
Registering of a client application or service to perform the bulk Payer-to-Payer Exchange should be registered in accordance with the approach defined in the SMART App Launch IG. That IG also encourages the use of the OAuth2.0 Dynamic Client Registration Protocol (DCRP). An alternative approach that is closely aligned with the DCRP protocol is to use the B2B protocols detailed in the HL7 Security for Scalable Registration, Authentication, and Authorization IG.
If the protocols detailed in the above UDAP Security IG's Business to Business) section are used, it is recommended that the subject_id in the B2B Authorization Extension Object (Key Name: "hl7-b2b") contain the NPI of the Provider for which Attributed Patient data is being requested. For instances where health plan generated attribution lists cover more than a single provider, the subject_id could be the FHIR Id of the Group being requested. The use of the Group FHIR ID as the subject_id is based upon the assumption that health plans have access controls in place to restrict the requestor to only having access to Group records they are authorized to access.
SMART App Launch STU2.1 defines granular scopes for resources. Following the model proposed in the section on FHIR Resource Scope Syntax the following scopes are proposed to control access to the Da Vinci Data Export Operation for Provider Access:
| system.Group.u?code=http://hl7.org/fhir/us/davinci-pdex/ValueSet/PDexMultiMemberMatchResultVS | pdexprovidergroup |
This would be the scope to execute the davinci-data-export operation with it being restricted to the Group id(s) that the user is authorized to access.
IG © 2024+ HL7 International / Financial Management. Package hl7.fhir.us.davinci-pdex#2.1.1 based on FHIR 4.0.1. Generated 2024-11-22
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