Stream: united states
Topic: Scope of the ONC rule in terms of FHIR IGs
René Spronk (Sep 01 2020 at 15:14):
As a European FHIR trainer, without having the wish to actually read the ONC final rule (who does, really?), the list of IGs associated with it seems pretty clear (there are many secondary sources for this).
However, it's less clear to me what the status of the Argonaut Clinical Notes IG would be, or the Argonaut Provenance IG. Are those to be understood as nice-to-have additional guidance on top of US Core - in terms of scope they seem to be within scope for the rule ? Other Argonaut IGs seem to be out of scope: provider Directory (STU3), scheduling, CDS Hooks, Questionnaires (based on SDC), Subscriptions (draft).
And: is CDS Hooks actually referenced/used in US Core ?
Yunwei Wang (Sep 01 2020 at 16:36):
US Core has guidance for Clinical Notes (https://www.hl7.org/fhir/us/core/clinical-notes-guidance.html) and Provenance (https://www.hl7.org/fhir/us/core/basic-provenance.html)
René Spronk (Sep 02 2020 at 09:47):
Thank you. One person rolled their eyes when reading my question - please remember that as a European I'm having to deal with dozens of different sets of legislations and "final rules", one or more for each European country (and elsewhere), so this US stuff is just another one in a loooong series. It's difficult to keep abreast if one isn't directly involved in the creation of a set of specs. ;-)
So one other final verification question on CMS, if I may: DaVinci Payer Data Exchange (PDex) US Drug Formulary STU 1 , is in-scope for the initial phase (right?), as is the FHIR Bulk Data Access Implementation Guide v1.0.0 (under CMS rules, not just under ONC rules) ?
Josh Mandel (Sep 02 2020 at 13:56):
The challenges of emoji-based communication -- I'm guessing that the eye roll emoji reaction was intended to express something like "I'm not sure, so I'm averting my eyes and looking for someone over on there in the corner who might know". You're doing a heroic job to keep track of all this, René!
Josh Mandel (Sep 02 2020 at 13:58):
For bulk data: as you point out this is required by ONC, for EHR vendors. I don't believe it's required for payors by the CMS rule -- but it'd be great to hear some confirmation, because overall I am less familiar here.
René Spronk (Sep 02 2020 at 14:20):
Ah yes, emoji semantics ;-)
Elliot Silver (Sep 02 2020 at 16:43):
René Spronk said:
Ah yes, emoji semantics ;-)
I smell a PhD thesis brewing.
Karl M. Davis (Sep 02 2020 at 17:36):
Yeah, as one of those folks, what I meant was "I'm looking at this" i.e. "interested in the question and what folks have to say." Apologies for cultural confusion.
(Graham was probably just being mean, though. He's like that. :wink: )
Grahame Grieve (Sep 02 2020 at 20:28):
I don't recall clicking on that, actually. But I will certainly remember this comment and be mean to @Karl M. Davis when the opportunity arises
René Spronk (Sep 03 2020 at 06:13):
Joking aside, back to the question at hand: Is there a requirement for FHIR Bulk Data Access Implementation Guide v1.0.0 (under CMS rules, not just under ONC rules) ?
Josh Mandel (Sep 03 2020 at 13:10):
https://www.cms.gov/newsroom/fact-sheets/interoperability-and-patient-access-fact-sheet reinforces my recollection that there is no requirement for bulk access from payors -- though it is worth pointing out that CMS itself is building out several bulk data apis for different use cases.
Josh Mandel (Sep 03 2020 at 13:12):
https://dpc.cms.gov/, https://bcda.cms.gov/, and https://ab2d.cms.gov/
René Spronk (Sep 03 2020 at 14:26):
OK, my take up to now, using a MURAL (you can use an anonymous login when prompted): https://app.mural.co/t/firely9202/m/firely9202/1598084038483/421d21a45b6ed7f44428f38374259edfdd9d6469 - part of the problem the rule isn't necessarily defined in terms of IGs (which is what happens in most countries), but that it's a set of requirements which has to be met by various groups/projects creating IGs. Groups/projects may have conflicting ideas as to what IGs one should implement to conform to the published rules. That's probably the reason as to why I'm seeing conflicting lists.
Anyway, the MURAL contains the IGs that seem to be a 'SHALL implement'. I'm aware that this glosses over some of the API rules currently not covered by any IG, but for educational purposes it's ok to cover the essential parts (remember the 80%), and "leave the remaining stuff / requirements" to the reader. As a trainer you can get away with that, not so as an implementer ;-)
Brendan Keeler (Jan 30 2021 at 15:08):
Coming late to this conservation but the eyes emoji commonly means "I'm looking/I'm interested"
Brendan Keeler (Feb 09 2021 at 07:05):
@René Spronk that mural link doesn't work for me. Is it still accurate?
Last updated: Apr 12 2022 at 19:14 UTC
