Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case Electronic Submission of Medical Documentation (esMD) eDoC eClinical Templates for Structured Data Capture on FHIR Use Case 7/15/2015 1 2 3 4 3/22/2016 1 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 5 6 Table of Contents 7 2.0 Initiative Overview .................................................................................................................................. 4 8 2.1 Initiative Challenge Statement............................................................................................................ 6 9 3.0 Use Case Scope ....................................................................................................................................... 6 10 3.1 Background ......................................................................................................................................... 6 11 3.2 In Scope ............................................................................................................................................... 8 12 3.3 Out of Scope........................................................................................................................................ 8 13 3.4 Communities of Interest ..................................................................................................................... 9 14 4.0 Value Statement ................................................................................................................................... 11 15 5.0 Use Case Assumptions .......................................................................................................................... 12 16 6.0 Pre-Conditions....................................................................................................................................... 12 17 7.0 Post Conditions ..................................................................................................................................... 13 18 8.0 Actors and Roles ................................................................................................................................... 13 19 9.0 Use Case Diagram ................................................................................................................................. 15 20 10.0 Scenario............................................................................................................................................... 16 21 10.1 User Story........................................................................................................................................ 17 22 10.2 Activity Diagram .............................................................................................................................. 17 23 10.2.1 Base Flow ................................................................................................................................. 18 24 10.2.2 Alternate Flow.......................................................................................................................... 19 25 10.3 Functional Requirements ................................................................................................................ 20 26 10.3.1 Information Interchange Requirements .................................................................................. 20 27 10.3.2 System Requirements .............................................................................................................. 20 28 10.4 Sequence Diagram .......................................................................................................................... 21 29 11.0 Risks, Issues and Obstacles ................................................................................................................. 22 30 12.0 Dataset Requirements ........................................................................................................................ 24 31 Appendices.................................................................................................................................................. 26 32 Appendix A: Related Use Cases.............................................................................................................. 26 33 Appendix B: Previous Work Efforts ........................................................................................................ 26 34 Appendix C: References .......................................................................................................................... 26 1.0 Preface and Introduction ........................................................................................................................ 4 35 3/22/2016 2 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 36 List of Figures: 37 Figure 1: Use Case Diagram ........................................................................................................................ 15 38 Figure 2: Context Diagram .......................................................................................................................... 16 39 Figure 3: Activity Diagram ........................................................................................................................... 18 40 Figure 4: Sequence Diagram ....................................................................................................................... 22 41 42 List of Tables: 43 Table 1: Communities of Interest .................................................................. 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Bookmark not defined. 44 Table 2: Actors and Roles ............................................................................................................................ 14 45 Table 3: Base Flow of Scenario 1................................................................................................................. 18 46 Table 4: Alternate Flow ............................................................................................................................... 19 47 Table 5: Information Interchange Requirements ....................................................................................... 20 48 Table 6: System Requirements ................................................................................................................... 21 49 Table 7: Dataset Requirements................................................................................................................... 25 50 51 3/22/2016 3 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 52 53 54 55 1.0 Preface and Introduction 56 57 58 59 60 61 62 63 To fully realize the benefits of health IT, the Office of the National Coordinator for Health Information Technology (ONC), along with the Centers for Medicare and Medicaid Services (CMS), as part of the Standards and Interoperability (S&I) Framework is developing Use Cases that define the interoperability requirements for high priority health care data exchange, in addition to maximizing efficiency, encouraging rapid learning, and protecting patients’ privacy in an interoperable environment. These Use Cases address the requirements of a broad range of Communities of Interest, including patients/beneficiaries, their significant others, and family members, in addition to providers, payers, vendors, standards organizations, public health organizations, and Federal agencies. 64 These Use Cases describe: 65 66 67 68 69 A. B. C. D. 70 71 72 The Use Case is the foundation for identifying and specifying the standards required to support the data exchange, as well as developing reference implementations and tools to ensure consistent and reliable adoption of data exchange standards. 73 74 75 76 77 78 2.0 Initiative Overview 79 80 81 82 83 84 85 86 87 88 89 Healthcare payers frequently request providers to submit additional medical documentation in order to adjudicate and support the processing of a specific claim or set of claims and perform other administrative functions, including identification of improper payments. Currently, Medicare Review Contractors send over 1 million requests for medical documents per year manually using a paper request letter to mail through the US Postal Service to healthcare providers. Until recently, healthcare providers had only two options for submitting the requested records to Medicare Review Contractors: 1) mail paper or 2) send a fax. The manual paper process is costly, time consuming and can delay proper claims processing on both the senders’ and receivers’ end. Section Description: The Preface and Introduction briefly explains the purpose of Use Case development as part of the Standards & Interoperability (S&I) Framework. A standard preface and introduction is required across all S&I Framework Initiative Use Cases (text included below). The operational context for the data exchange The stakeholders with an interest in the Use Case The information flows that must be supported by the data exchange The types of data (structured/unstructured, etc.) and their specifications required in the data exchange Section Description: This section articulates the overarching issues that the Initiative aims to address. The Initiative’s goals are at a higher level than those of the Use Case and are distinguished as such in this section. If an Initiative has multiple Use Cases, this Initiative Overview should be consistent for each Use Case. Note: A recommended starting point for this content is the project charter and related research collected during the Pre-Discovery phase. As of September 15, 2011, a pilot group of Health Information Handlers (HIHs) and Medicare Review Contractors began accepting electronic submissions from providers, as part of the first phase of esMD. 3/22/2016 4 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 These electronic submissions consist of an unstructured .PDF format of a scanned image, within an Integrating the Healthcare Enterprise Cross-Enterprise Document Reliable Interchange (IHE XDR) wrapper. This initiative will provide added value to CMS, Commercial Payers, and Providers by defining the interoperability requirements for additional automation of the electronic request and submissions process. CMS continues to investigate additional capabilities of electronic submission of medical documentation. The next release for CMS esMD Phase 2 will enable Medicare Review Contractors to send electronic medical documentation requests (eMDRs), eliminating the need to send the paper letters via mail or fax. CMS joined the Standards & Interoperability (S&I) Framework to accomplish their short-term goals for Phase 2 and to address their long-term requirement for replacement of wet signatures with digital signatures. In joining the S&I Framework, esMD stakeholders were broadened beyond CMS to include discussions with other payers in the esMD Community including Commercial Payers. With a goal of promoting consistency across payers and standardizing processes for beneficiaries and providers dealing with multiple payers, the requirements of multiple payer entities were incorporated into esMD Use Cases. esMD expanded Initiative capabilities to support electronic Determination of Coverage (eDoC). For example, CMS believes the Prior Authorization of Power Mobility Devices (PMDs) Demonstration will lead to reductions in improper payments for power mobility devices. In addition, this demonstration is designed to develop and demonstrate improved methods for the determination of coverage for the provision of care or services under the health programs established by the Social Security Act. The key objectives for the overall S&I Framework esMD Initiative include: 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 A. Develop a registration process to allow Providers to sign up to receive electronic medical documentation requests from CMS Review Contractors Identify a secure method of sending medical documentation requests from CMS review contractors to providers C. Identify a solution that will enable an electronic replacement of wet signatures, for medical documents submitted from providers to CMS D. Identify standards-based, machine-interoperable electronic structured document templates to provide an alternate electronic method using SDC for the current paper versions of documentation for determination of coverage B. In order to address the objectives above, this Initiative included the following workgroups: i. Provider Profiles Authentication (PPA) workgroup: Addresses the registration process, technical transport and authentication needed to allow Payers to identify Providers and send requests to them. This workgroup is dependent on the Provider Directories Use Case #2 (Electronic Service Information Discovery) outputs, as well as the Exchange support (for the CMS User Story) for secure transport and other infrastructure. ii. Structured Content (SC) workgroup: Determines the structured electronic format of medical document request letters to be sent to Providers, with consideration for the technical transport, expected response and information needed to support the response. 3/22/2016 5 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 133 134 135 136 137 138 iii. Author of Record (AoR) workgroup: Evaluates the business needs and implementable solutions to address the ability to prove the authorship and authenticity of any message or documentation that is part of the electronic submission of medical documentation. This includes all messages that are part of provider registration (esMD UC 1), the electronic submission of the structured medical documentation request (esMD UC 2) and the response by the provider or their agent to the payer or payer contractor. 139 140 141 142 143 iv. Electronic Determination of Coverage (eDoC) workgroup: Defines coverage determination documentation requirements as structured data sets and templates. This includes defining data sets, templates, and standards, in addition to providing guidance with decision support, enabling provider capture of required structured documentation, and establishing secure exchange for benefit determination. 144 145 146 147 2.1 Initiative Challenge Statement 148 149 150 151 152 153 154 The Centers for Medicare and Medicaid Services (CMS) and other Health Plans/Payers need a standardized, implementable, machine-interoperable electronic solution to reduce the time, expense, and paper required in current manual processing of medical documentation request letters, responses to medical documentation requests, determination of coverage requests, and the relevant medical documentation exchanged between Healthcare Providers and Health Plans/Payers. The challenge at hand is to identify the data set requirements for structured documentation required by CMS and other Health Plans/Payers for processing of coverage determination. 155 156 157 158 159 160 161 3.0 Use Case Scope 162 163 164 165 166 167 This Use Case specifically addresses the structured content requirements to process determination of coverage. Although coverage determination requirements may only be applicable to CMS, the eDoC workgroup determined that it would be beneficial for all Payers to follow a consistent process to identify coverage data set requirements. This Use Case therefore includes input from a variety of stakeholders to validate that the structured data sets, templates, and standards outlined apply to a broad Payer and Provider community. 168 169 While the eDoC General Use Case outlines the high-level requirements for coverage determination documentation, this Use Case will specifically leverage the Structured Data Capture(SDC) IHE and HL7 Section Description: This section provides the description of the current challenge or problem, on a healthcare industry level, that the Initiative seeks to address. Related issues that currently exist should be included within this section, with the exception of risks, which are outlined later in the Use Case. Section Description: Section 3.0 is used as an introduction to the scope of the Use Case. Sections 3.1-3.3 further define the scope at a more granular level. It is a useful exercise to frequently validate that all material in this section focuses specifically on the Use Case scope and NOT on the Initiative Scope. If there are multiple Use Cases within the same Initiative, this section can be used to explain how the scope of this Use Case relates to the others. Note: In the past, diagrams and other supplemental data / examples have helped to provide context and clarify the basis for the Use Case. 3/22/2016 6 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 170 171 172 173 174 175 standards, including the HL7 Fast Health Interoperability Resource (FHIR) standard, to define questions and responses used to support CMS eClinical Templates, establish pre-population of responses to predefined questions based on data within the EHR, and modify or expand upon pre-populated responses. To exchange the contents generated using SDC standards, the HL7 Complete Documents for Payers Set 1 standard will be leveraged, in addition to the HL7 digital signature standard to verify authorship and delegation of rights. 176 This effort will include investigating and recommending solutions for: 177 178 179 i. ii. iii. Structured Data – Data Set requirements Structured Data Capture Documentation Templates – Data Capture requirements Decision Support related to documentation capture workflow – Template workflow 180 181 182 183 184 3.1 Background 185 186 187 188 189 CMS is developing eClinical Templates which define categories of clinical information to assist providers with data collection and medical documentation to support payer coverage for planned or rendered services and devices/items. The categories of clinical information are not intended to be required, but rather serve as guidance for the physician or treating practitioner to use to create electronic medical documentation in support of coverage for an item or service. 190 191 192 193 194 The purpose of the eDoC workstream is to define structured documentation data sets which may include coded and un-coded data elements and the associated clinical vocabularies or code sets that should be used, along with appropriate narrative, or unstructured, descriptions. These templates will provide the basis to enable providers to capture structured documentation, and securely exchange this documentation for benefit determination based on Health Plan/Payer’s coverage and payment rules. 195 196 This eDoC workstream will define specific requirements with respect to Structured Data, Documentation Templates and Template Workflow, including addressing the following key challenges: 197 198 199 200 201 202 203 A. Define coverage determination documentation requirements for structured data sets and exchange templates B. Define standards enabling providers to capture documentation based on payer requirements C. Define template workflow to facilitate provider documentatation D. Define use of digital signatures on transactions and documents where appropriate E. Determine secure content exchange standards for exchange of documentation between payers, providers, and suppliers 204 205 Section Description: The Background section goes into more detail than the Initiative Overview to describe the relevance of the Use Case in relation to what gaps currently exist within the healthcare industry. All policy and/or regulatory issues as well as dependencies that may impact the Use Case should be included in this section. These challenges will be addressed by leveraging work that has already been completed by related S&I Framework Initiatives such as Transitions of Care (Consolidated CDA), Provider Directories, Structured 3/22/2016 7 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 206 207 Data Capture, Longitudinal Coordination of Care (LCC), and esMD, in addition to other ONC efforts such as Direct and CONNECT. 208 209 210 211 212 213 3.2 In Scope 214 215 216 217 218 219 This workgroup will focus on defining the use case, user stories and requirements supporting a standards-based architecture. It will reuse existing S&I Initiative efforts, including the Structured Data Capture Initiative, where possible in the process of selecting standards for structured data documentation requirements, exchange templates, interactive information capture templates, decision support rules and exchange standards. For the immediate effort to determine documentation requirements the use case will: 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 242 243 244 245 246 Section Description: This section indicates what is in scope for the Use Case. For example, it can include the type of transactions, the information/data to be exchanged, and specific aspects that need to be in place to enable the information to be sent, received and understood the same at both ends of the transmission. Note: A suggested starting point for this content is the project charter and related research collected during the Pre-Discovery phase. A. Evaluate and specify appropriate clinical elements for inclusion in eDoC SDC templates B. Represent eDoC user stories for specific services and devices/items and their eClinical Templates as SDC templates for coverage determination C. Map CMS eClinical Template concepts onto SDC template data elements D. Define acceptable responses, where appropriate, for CMS eClinical Templates using structured data capture E. Define clinical data elements (CDE) that may be pre-populated F. Evaluate existing FHIR resources and profiles to address the gaps in supporting “A”-“E” above G. Define FHIR resources and profiles required to address the gaps identified in “F” H. Where gaps exist between eClinical Template concepts and SDC data elements, define clinical data elements using, where possible, standard clinical vocabularies I. Identify persistence of templates and responses J. Identify standards for exchange of persisted templates and responses K. Identify requirements for information exchange between providers and payers that can be used during harmonization to specify appropriate transaction/message standards L. Define provenance elements associated with information used in the determination of coverage both created by the provider interacting with the SDC template and information that may be incorporated from other sources M. Define digital signature requirements to support provenance and data integrity 3.3 Out of Scope Section Description: This section indicates what is out of scope for the Use Case. These points may highlight dependencies on the feasibility, implementability, and usability that result in limitations of the Use Case. At a high level, whatever is not declared “In Scope,” is by definition, “Out of Scope”. Note: There may be some items that are out of scope for the Use Case and Functional Requirements Development as well as the Standards Harmonization activities, that can be included as part of a Pilot. These additions will be documented during that particular stage of the S&I Framework process; however, this expansion should not conflict with the previously defined requirements. 3/22/2016 8 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 247 248 249 250 251 252 253 A. Provider documentation (with the exception of supporting documentation as defined above in the In Scope section) that do not use the templates or standards specified by this use case and its subsequent implementation guides B. Electronic exchange between the Beneficiary and Payer/Payer Contractor C. The capture and reporting of information specifically for quality measures is considered out of scope until such time as the electronic Determination of Coverage Use Case specifically declares it in scope. 254 255 256 257 258 3.4 Communities of Interest 259 260 Click here to view the list of definitions: http://wiki.siframework.org/UC+Simplification++Stakeholder+Classification+SWG 261 262 The Communities of Interest section identifies relevant stakeholders that are potentially affected by the content of the Use Case. 263 Note - All items pulled from the Use Case simplification tables are marked with an asterisk. Some have 264 265 266 been further modified to fit the working definition or newly added to fit the initiative or Use Case needs. Click here to view the list of definitions: http://wiki.siframework.org/UC+Simplification++Stakeholder+Classification+SWG. Section Description: The Communities of Interest section identifies relevant stakeholders that are potentially affected by the content of the Use Case. This list may vary per Initiative, but the stakeholder definitions will be consistent throughout the S&I Framework, as defined by the Use Case Simplification Workgroup (examples included below). 1 Members of Communities of Interest Individual Providers 2 Provider Organizations* 3 Healthcare Administrators and Managers 3/22/2016 Working Definition Healthcare providers with beneficiary care responsibilities including, but not limited to, physicians, advanced practice nurses, physician assistants, nurses, psychologists, emergency care providers, home health providers, definitive care providers, pharmacists and other personnel involved in beneficiary care. Organizations that are engaged in or support the delivery of healthcare to include Hospitals, Ambulatory Centers, Provider Practices, Integrated Delivery Networks, and Rehabilitation Centers. Healthcare administrators with beneficiary information and medical records management responsibilities including Health Information Management (HIM) personnel, Registered Health Information Administrator (RHIA), Registered Health Information Technicians (RHIT), Inpatient/Outpatient Clinical Coding Specialists, Medical Transcription Specialists, Medical Records Safety and Security staff, Quality Control personnel, Physician Practice Managers, Pharmacy Benefit Managers, and other management personnel or entities involved in managing beneficiary information. 9 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 4 Members of Communities of Interest Payer Contractors 5 Payers* 6 EHR/EMR/PHR Vendors* 7 Additional Healthcare Vendors* 8 Additional Healthcare Suppliers 9 Beneficiaries* 10 Standards Organizations* 3/22/2016 Working Definition Claims review programs and/or their specific implementation through associated contractors and their subcontractors that are established to prevent improper payments before a claim is processed as well as identify any improper payments that can be recovered after a claim is paid. These programs include but are not limited to: MAC- Medicare Administrative Contractors MRA –Medicare Recovery Auditor (formerly Recovery Audit Contractors, RAC) PERM – Payment Error Rate Measurement Program SMRC – Supplemental Medical Review Contractor CERT –Comprehensive Error Rate Testing Program ZPICS – Zone Program Integrity Contractors UMO – Utilization Management Organization Any private or public entity that finances heath care delivery or organizes health financing. This includes commercial for-profit health insurers, non-profit health insurers, ERISA self-insured, state and federal department agencies that oversee Medicaid and Medicare health services delivery. Vendors which provide specific EHR/PHR solutions to clinicians such as software applications and software services. These suppliers may include developers, providers, resellers, operators, and others who may provide these or similar capabilities. Vendors that provide health care solutions other than EHR/EMR/PHR solutions such as software applications and services. Examples include: integration vendors, data providers, medical device vendors, RMMS (Remote Monitoring Management System) vendors, diagnostic imaging service provider, clinical order system supply vendor, transcription service vendors, clearinghouses, drug knowledge suppliers, network infrastructure provider, Clinical Decision Support (CDS) resource system, practice-based registry system suppliers, public health registry system, immunization information system providers, clinical genetic database/repository system vendor, practice management systems, beneficiary accounting systems, and utilization management, etc. Medical suppliers providing services or devices to the beneficiary, including but not limited to, Durable Medical Equipment Suppliers, Clinical Laboratories, Oxygen Suppliers, etc. Members of the public who receive healthcare services from, but not limited to, ambulatory medical and/or surgical departments, emergency department, physician’s and/or Non-Physician Provider’s (NPP) office; inpatient hospitals including Critical Care Hospitals and the VAH, Medical Home Care Models, Home Health and Hospice (HHH) entities that provide care within the beneficiary’s home environment; and/or a public health agency/department, including services provided within the criminal justice system. Organizations whose purpose is to define, harmonize and integrate standards that will meet clinical and business needs for sharing information among organizations and systems 10 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 11 Members of Communities of Interest Licensing and Certification Organizations* 12 Operating Rule Authoring Entities 13 Beacon Communities* 14 Federal Agencies* 15 Agent – [Healthcare Clearinghouses and Business Associate and their subcontractors as defined by Health Insurance Portability and Accountability Act (HIPAA) including Health Information Handlers] Health Information Organization (HIO)* 16 17 Regional Extension Centers (REC)* 18 Health Information Service Providers (HISP)* 267 268 269 270 271 Working Definition Federal, Nationally approved and State Licensure Boards and local organizations, including accredited teaching academies, responsible for developing guidelines for Implementation, providing Licensure and defined scope of practice (healthcare services), to ensure that relevant parties qualify and adhere to those guidelines, ensuring proper licensing and certification under systems and other healthcare solutions related to delivery of safe healthcare services As defined in Affordable Care Act Section 1104, such entities develop operating rules that define the necessary business rules and guidelines for the electronic exchange of information that are not defined by a standard or its implementation specifications. Rules developed under ACA Section 1104 may not necessarily apply to this Use Case. Selected communities of groups who have received federal funding through the ONC to build and strengthen their health information technology (health IT) infrastructure and exchange capabilities to improve care coordination, increase the quality of care, and slow the growth of health care spending. Organizations within the federal government that deliver, regulate or provide funding for health and health care Any organization that handles health information on behalf of a provider as a covered entity or under a Business Associate Agreement (BAA) is an Agent. Many providers already use Agents to submit claims, provide electronic health record systems, etc. Organizations that are Agents include but are not limited to Healthcare Clearinghouses, Release of Information vendors, Health Information Exchanges, Electronic Health Record vendors, etc. HIOs are the management organizations that provide Health Information Exchange (HIE) services which are defined as the mobilization of healthcare information sent electronically across organizations within a region, community or hospital system Entities that support and serve health care providers to help them quickly become adept and meaningful users of electronic health records (EHRs). RECs provide training and support services to assist doctors and other providers in adopting EHRs, offer information and guidance to help with EHR implementation, and give technical assistance as needed. Entities that serve as a node on the National Health & Information Network to enable a private, secure and safe alternative method to send and receive sensitive health information. Table 1: Communities of Interest 4.0 Value Statement Section Description: This section provides the high level description of the value and/or benefit of this Use Case to the healthcare community. This section also identifies the anticipated outcomes and the metrics that will be used to assess the success of the Use Case. 3/22/2016 11 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 272 273 274 275 276 277 The value of the esMD Initiative will be to provide consensus-based use cases, functional requirements, standards references and implementation specifications/guidance representing combined input from a broad range of stakeholders, including CMS, commercial Health Plans/Payers, Providers, and vendors. This will promote a nationally standardized approach to structured and unstructured data requirements for the electronic Determination of Coverage and the proof of validity and authorship of relevant medical documentation. 278 279 280 281 Health Plans/Payers and Providers will benefit from this workgroup’s implementation guidance on electronic determination of coverage, by moving away from current unstructured (paper and images of medical documentation) information for selected specific use cases pertaining to services and devices. Benefits include, but are not limited to: 282 283 284 285 286 287 288 289 290 291 292 A. Standardized data sets, templates, and secure exchange of required documentation to meet 293 294 295 296 Further, the use of structured data capture and FHIR standards will enable CMS and other Payers to request or remind providers of specific information that may not exist in the medical record at the time of template execution to facilitate creation of appropriate documentation required for coverage determination. 297 298 299 300 301 5.0 Use Case Assumptions 302 303 304 305 306 307 308 309 310 311 B. C. D. E. F. G. H. I. payer coverage and payment rules Utilization of structured data capture to facilitate the collection of service specific information Improved ability to support complex logic in the collection of procedure/service specific information and the initial determination of covered service options Saving time, money and resources for CMS, Commercial Health Plans/Payers, and Providers Elimination of the paper or unstructured data processing and its associated labor and error rate Reduction of improper payment Improved accounts receivable cycle for Providers, so payments are received sooner Reduced time for benefit determination and notification from Payer to Provider Reduced staff time spent handling paper, printing, imaging and mailing Section Description: The Use Case Assumptions section outlines what needs to be in place to meet or realize the requirements of the Use Case (i.e. the necessary privacy and security framework). These points are more functional in nature and state the broad overarching concepts related to the Initiative. The Use Case assumptions will serve as a starting point for subsequent harmonization activities. A. The structured data required to design SDC templates is defined in the eDoC General Use Case and specific user stories. B. SDC template libraries are available to support and respond to queries for SDC templates C. The provider “knows” how to request and interact with an SDC template D. For CMS Medicare FFS, this Use Case addresses the data requirements for determination of coverage, as identified within CMS eClinical Templates For other Payers, their documentation requirements will determine data set requirements for structured data capture F. Multiple valid diagnostic, documentation, and order workflows currently exist, including those of various Providers and Service Suppliers E. 3/22/2016 12 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 312 313 314 315 316 317 318 319 320 321 322 323 324 325 326 327 328 329 330 331 332 333 334 335 336 337 338 339 340 341 342 343 344 345 346 347 348 349 350 351 G. All actors have secure access to their information systems (e.g. Providers having access to H. I. J. K. L. M. N. O. create/update beneficiary records in an EHR system) The identity of the provider interacting with the template, as well as the date and time, is captured and stored in the medical record at the time the interaction is completed Electronic transaction based exchanges must be supported between all of the actors of this Use Case All data collected and submitted for coverage determination must be a permanent part of the beneficiary’s medical record maintained by the responsible provider/supplier All actors shall create all transactions utilizing current industry accepted standards All transactions will be compliant with existing security standards to ensure data is transmitted with integrity, confidentiality, and reliability All actors and systems shall ensure all transactions will be delivered in a timely manner All required declarations of conflict of interest as determined by the relevant payer policies must be available All documentation and transactions created as part of this use case should have Author of Record (AoR) L1 or L2 Digital Signatures as appropriate 6.0 Pre-Conditions Section Description: The Pre-Conditions section describes the state of the system, from a technical perspective, that must be true before an operation, process, activity or task can be executed. It lists what needs to be in place before executing the information exchange as described by the Functional Requirements and Dataset requirements. A. All Actors, as defined in this Use Case, shall have their respective systems maintain the ability to exchange information as required by this use case. B. SDC Template library is available and accessible to the requesting EHR C. The EHR “knows” the address of the SDC template library D. The EHR has the ability to request, pre-populate, and present SDC templates E. The EHR has the ability to record and store answers in response to SDC templates F. The EHR will always give the provider the option of using the most recent version of a specific template in the SDC Template Library G. Actors that utilize digital signatures, as defined in this Use Case, have the ability to create and sign the documentation defined by this use case – this may be implemented in the EHR or as a third party service H. The Physician and Physician-Referred Entity EHR systems that utilize digital signatures have and maintain the ability to use esMD AoR compliant Digital Signatures to attest to the actions taken on required documentation 7.0 Post Conditions Section Description: The Post Conditions section describes the state of the system, from a technical perspective, that will result after the execution of the operation, process activity or task. A. Completed SDC template information is stored in the beneficiary’s medical record in the EHR B. The stored SDC template information is available to the provider as part of the medical record 3/22/2016 13 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 352 353 354 355 356 357 358 C. The stored SDC template data elements are available to down-stream applications D. EHR populates CDP1 externally defined clinical data element section with stored SDC template data elements prior to exchanging CDP1 for the eDoC General Use Case E. Payer or Payer Contractor information system should validate AoR Level 1 or Level 2 (as appropriate) digital signatures and Delegation of Rights Assertions F. Recipient’s receiving system must be able to consume and process the signed, completed template (e.g. – storage, forwarding, adjudication, etc.) 359 360 361 362 8.0 Actors and Roles 363 364 365 366 The business actor must use a system to perform the functions and to participate in the information interchange. The system or system actor has roles (send, receive, publish, subscribe or in some cases display) and actions which involve exchanging content. Please see the table below for an example of these designations. 367 NOTE: A Business Actor may be a Stakeholder and also can have more than one role. Section Description: This table outlines the business actors that are participants in the information exchange requirements for each scenario. A business actor is a person or organization that directly participates in a scenario. Thus, as a person or organization, the actor can (and should) be a stakeholder. Actor Provider System EHR System SDC Template Library Template Library System EHR Database EHR System 368 Role Send request for SDC Template Receive SDC Template Display pre-populated SDC Template Modify and complete SDC Pre-Populated Template Approve completed template Digitally sign completed template Access completed templates within the EHR Database Optionally sends completed template to intended recipient Receive request for SDC Template Send SDC Template to EHR System Saves completed SDC Template as part of beneficiary’s medical record Provides access to template Table 2: Actors and Roles 3/22/2016 14 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 369 370 371 372 373 9.0 Use Case Diagram 374 375 376 377 378 379 The Use Case diagram shows the association and interaction between the business actors and the Use Case. It provides an overview of the actors (users or external systems), Use Cases, and the interactions between them. The context diagram uses inputs and outputs to provide a pictorial representation of the environment, both internal and external, where the exchange takes place. As the UML associated with the diagrams proceeds through the different S&I Framework functions (i.e., Harmonization, Reference Implementation), it is defined at a more granular level closer to the coding (implementation). Section Description: This section conceptually represents the Business Actors interacting with the Use Case and the User Stories. These diagrams characterize the types of interactions that an actor has with a specific system. The section can include a Use Case Diagram and, if applicable, a Context Diagram (examples are shown below). Use Case Diagram Provider Selects template Accesses the completed template within EHR Database Template Library System Receives request for template Sends template to the EHR System Modifies/completes/ approves, and optionally, digitally signs completed template Sends request for template Receives template Pre-populates template Displays Pre-populated template Saves completed template as part of beneficiary’s medical record Provides access to template Optionally sends completed template to intended recipient Stores completed template EHR System EHR Database 380 381 Figure 1: Use Case Diagram 3/22/2016 15 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 382 383 Figure 2: Context Diagram 384 385 386 387 388 389 390 10.0 Scenario 391 Suggested Format: Paragraphs 392 393 394 395 396 397 398 399 400 This eDoC Use Case focuses on the functionality and interoperability required for a provider to retrieve an eClinical Template from an external template library, auto-populate data within the template with information from the beneficiary’s electronic health record (EHR), enter additional data into the eClinical Template, digitally sign the eClinical Template, and save and store the completed eClinical Template within the EHR system using a standard format. Optionally, the Provider may opt to send the completed eClinical Template to a party of their choice, including the Payer, directly after digitally signing the template. The standard format of the eClinical Templates could be used as a means to provide data to end users. Data captured shall also be stored in the EHR associated with the individual beneficiary and encounter as part of the permanent medical record. Section Description: The scenario is a comprehensive description of the actors, interactions, activities, and requirements associated with the information exchange. It is a prototypical sequence of interactions in a business collaboration or the application context. Scenarios pertain to supporting the health information exchange and, describing key flows, and are supplemented by User Stories (example shown below). Section 10.0 serves as an introductory section while sections 10.1 through 10.5 provide more specific details (examples shown below in all sections). 3/22/2016 16 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 401 402 403 404 405 10.1 User Story 406 Suggested Format: Paragraphs 407 408 409 410 411 412 413 414 415 416 417 418 419 A beneficiary has a face-to-face visit with their physician provider. The Provider evaluates and assesses the Beneficiary and determines the beneficiary is in need of a service or device eligible for coverage determination. The Provider sends a request for the appropriate template from the EHR System to the SDC Template Library. The SDC Template Library receives the request from the EHR System. The SDC Template Library sends the requested template to the EHR System. The EHR System receives the template from the SDC Template Library. Where appropriate, the EHR System pre-populates the template with information from the beneficiary’s medical record. The pre-populated template is displayed for the provider to input additional clinical information and/or to modify the pre-populated information. The provider approves, optionally digitally signs, and saves the completed template for the EHR System to store the completed template within the EHR System database/storage infrastructure as part of the beneficiary’s medical record. The EHR System optionally sends the completed, approved, and signed template, along with other relevant clinical documentation, to the Payer or other intended recipient. 420 421 422 423 424 10.2 Activity Diagram 425 426 427 The Activity Diagram illustrates the Use Case flows graphically, and represents the flow of events and information between the actors. It also displays the main events/actions that are required for the data exchange and the role of each system in supporting the exchange. Section Description: User Stories summarize the interaction between the actors of the Use Case, and specify what information is exchanged from a contextual perspective. Furthermore, the User Stories describe the real world application as an example of the Scenario. These interactions are further described in subsequent sections. Historically, user stories have been utilized to provide clinical context Section Description: An Activity Diagram is a special form of a state transition diagram in which all or most of the states are activity states or action states. An action state represents the fulfillment of associated responsibilities in response to the communication received from the previous step. Most transitions are triggered by completion of activities in the source states. 428 3/22/2016 17 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case eDoC eClinical Templates for SDC on FHIR: Activity Diagram Provider EHR System Template Library System Start 1. Selects the appropriate template within the EHR System 2. Sends a request for template to the Template Library System 6. Pre-populates the template within the EHR System 9. Inputs additional data and/or modifies template 8. Accesses prepopulated template within the EHR System 5. Receives the template from the Template Library System 4. Sends the requested template to the EHR System 7. Displays the prepopulated template within the EHR System 11. Stores the completed template within the EHR Database as part of the beneficiary’s medical record 10. Approves, optionally digitally signs, and saves the completed template 3. Receives the request from the EHR System 12. Optionally sends the completed, approved, and signed template, along with other relevant clinical documentation, the Payer or intended recipient. End 429 430 Figure 3: Activity Diagram 431 432 433 434 435 10.2.1 Base Flow Section Description: The Base Flow presents the step by step process of the information exchange depicted in the activity diagram (above). It indicates the actor who performs the action, the description of the event/action, and the associated inputs (records/data required to undertake the action) and outputs (records/data produced by actions taken). 436 Suggested Format: Table Step # 1 2 3 4 Actor Provider/ EHR System EHR System SDC Template Library SDC Template Library 3/22/2016 Role Event/Description Selects the appropriate template within the EHR System Sends a request for template to the SDC Template Library Inputs Receiver Receives the request from the EHR System Requested Template Sender Sends the requested template to the EHR System Selector Sender Outputs Template selection Request for template Requested template 18 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case Step # Actor 5 EHR System 6 EHR System 7 EHR System 8 Provider/ EHR System 9 Provider/ EHR System 10 Provider/ EHR System 11 EHR Database Role Event/Description Receives the template Receiver from the SDC Template Library Pre-populates the Data template within the Entry EHR System Displays the preDisplayer populated template within the EHR System Accesses prepopulated template Receiver within the EHR Database Inputs additional data Modifier and/or modifies template Approves, optionally Approver/ digitally signs, and Signer saves the completed template Stores the completed Retainer template within the EHR Database 437 Inputs Outputs Requested Template Requested Template Pre-populated template Pre-populated template Displayed template Displayed Template Displayed Template Completed modified template Completed template Approved, digitally signed, completed template Approved, digitally signed, completed template Table 3: Base Flow of Scenario 1 438 439 440 441 10.2.2 Alternate Flow Section Description: An Alternate Flow describes a series of events that are related to the scenario but present a new pathway for the information exchange. Alternative flows can be used to capture error messages returned if the data are unavailable or not permitted to be shared. 442 Suggested Format: Table 443 444 Note: All steps 1-11 in the Base Flow apply to the alternate flow. Step 12 below is in addition to steps 111 in the Base Flow. Step # 12 Actor Role EHR System Sender 445 Event/Description Optionally sends the completed, approved, and signed template, along with other relevant clinical documentation, to the Payer or other intended recipient Inputs Outputs Approved template Table 4: Alternate Flow 3/22/2016 19 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 446 447 448 449 450 451 10.3 Functional Requirements 452 453 454 455 10.3.1 Information Interchange Requirements Section Description: The Information Interchange Requirements define the system’s name and role. They also specify the actions associated with the actual transport of content from the sending system to the receiving system. 456 Suggested Format: Table Section Description: Functional Requirements identify the capabilities a system in a role must have in order to enable interoperable exchange of the healthcare data of interest. They provide a detailed breakdown of the requirements in terms of the intended functional behaviors of the application. The Functional Requirements include Information Interchange Requirements, System Requirements and Dataset Requirements as indicated in sections 10.3.1-10.3.3 below. Initiating System (describes action) EHR System Send SDC eClinical Template Library EHR System Send EHR System EHR System (optional) EHR System (optional) Information Interchange Requirement Name Request for eClinical Template Requested eClinical Template (describes action) Receiving System Receive Receive SDC eClinical Template Library EHR System Prepopulates Complete/ update prepopulated template Apply digital signature Pre-Population of Template with EHR data Display template for provider completion/update Display EHR System Save/Store completed template EHR System/EHR Database Digitally signed eClinical Template EHR System/EHR Database Send Completed, signed eClinical Template Save/Store completed, digitally signed template Receive Payer/Other Party System 457 Table 5: Information Interchange Requirements 458 459 460 461 10.3.2 System Requirements Section Description: This section lists the requirements internal to the system necessary to participate successfully in the transaction. System requirements may also detail a required workflow that is essential to the Use Case. 462 Suggested Format: Table System 3/22/2016 System Requirement 20 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case System EHR System EHR System EHR System SDC eClinical Template Library SDC eClinical Template Library SDC eClinical Template Library SDC eClinical Template Library SDC eClinical Template Library SDC eClinical Template Library EHR System EHR System EHR System EHR System EHR System EHR System (optional) EHR System/EHR Database EHR System/EHR Database (optional) EHR System (optional) EHR System EHR System 463 464 465 466 467 468 469 System Requirement Provide for ability to select a specific eClinical template Maintain real-time updates and connectivity with SDC eClinical Template Library Send request for eClinical Template Be available for connectivity to and access by EHR System Receive eClinical Template request from EHR System Correctly identify requested template in standard format Send the correct requested template in standard format Update existing templates Receive and store new templates Receive eClinical Template from library Auto-population of displayed template with EHR-derived patient data Incorporate structured data in standard format into template Display an editable template containing pre-populated patient data Support provider interaction with editable template Optionally digitally sign completed template Incorporate the template information into the beneficiary’s medical record Optionally save and store the completed template in standard format Send completed and signed template to defined recipient (Payer/other) Has capability of identifying the author of record of a completed template as metadata associated with the template Has capability of identifying the recipient of a template from metadata with the template Table 6: System Requirements 10.4 Sequence Diagram Section Description: A Sequence Diagram is primarily used to show the interactions between objects in the sequential order that they occur. This representation can make it easy to communicate how the exchange works by displaying how the different components interact. The primary use of the diagram is in the transition from requirements expressed as use cases to the next and more formal level of refinement. Note: Horizontal lines are used to identify the specific activity between the systems. 3/22/2016 21 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case Provider (EHR System) SDC Template Library System EHR System 1. Selects the appropriate template within the EHR System 2. Sends a request for template to the Template Library System 3. Receives the request from the EHR System 4. Sends the requested template to the EHR System 5. Receives the template from the Template Library System 6. Pre-populates the template within the EHR System 7. Displays the pre-populated template within the EHR System for modification 8. Accesses pre-populated template within the EHR Database 9. Inputs additional data and/or modifies template 10. Approves, optionally digitally signs, and optionally saves the completed template 11. Stores the completed template and other relevant information within the EHR Database as part of the beneficiary’s medical record 12. Optionally sends completed, approved, and signed template, along with other relevant clinical documentation, to the Payer or intended recipient Provider (EHR System) 470 471 EHR System SDC Template Library System Figure 4: Sequence Diagram 472 473 474 475 476 11.0 Risks, Issues and Obstacles 477 Suggested Format: Paragraphs, Bulleted List Section Description: The Risks, Issues and Obstacles section lists the concerns that might interfere with meeting the requirements of the Use Case. Any Initiative wide points should be made above between both the Initiative Overview and the Initiative Challenge Statement sections. The information within this section will be vital to the harmonization activities. 3/22/2016 22 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 478 479 480 481 482 483 484 485 486 487 488 489 490 491 492 493 494 495 496 497 498 499 500 501 502 503 504 505 506 507 508 509 510 511 512 513 514 515 516 517 518 Risks/Issues A. Ensuring secure, trustable communications between providers, template libraries, technology B. suppliers, as well as the intended recipient of the completed template The burden to individual providers to obtain and manage digital signing certificates a) The ability to obtain and manage digital signing certificates may deter providers from participating in the transactions as outlined in this use case b) Risks associated with the digital identity process Compliance with Identity Proofing Requirements Compliance with Certificate Lifecycle (including revocation) Compliance with Delegation of Rights (including validation/revocation) Issues inherently in the creation and use of X.509v3+ Digital Certificates C. Dependencies on schedule of and deliverables from the HL7 and S&I SDC initiatives D. Unintended disclosure of Personal Health Information E. Ensuring consistent and reliable mechanisms for establishing and updating documentation requirements from changing payer payment policies F. Availability of solutions to solving technical, operational, and/or financial barriers preventing platforms, systems, and/or services from having adequate capacity and logic to accommodate the volume of eDoC transactions G. Overwriting/updating existing information H. Duplicate data entry I. Accuracy and reliability of EHR data J. Inaccurate data pulled into the template during auto-population from a patient’s previous visit Obstacles A. Compliance with NIST, FIPS, and FISMA in sending PHI from Providers to Federal Agencies and B. C. D. E. F. G. H. I. J. K. their agents Compliance with HIPAA in sending PHI from Providers to intended recipients Policy regarding signatures and/or provenance of documentation Identifying implementable solutions to establish provenance that minimize burden to Providers Lack of vendor (PMS and EMR) engagement in process a) Insufficient engagement and participation by vendor communities, and eventual adoption in Certified EHR products b) Insufficient commitment and lack of participation by various vendors and organizations in pilots Technical, operational, and/or financial barriers preventing platforms, systems, and/or services from having adequate capacity and logic to accommodate the volume of eDoC transactions Accessibility of a template library or repository Identification of a useful set of data elements for templates that can auto-populate with data extracted from the existing EHR Standards and solutions may not scale to small HIT vendors and small practices Not all EHR systems offer or can support auto-population functionality Lack of standardized format of EHR data, including structured and coded data 3/22/2016 23 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 519 520 521 522 523 524 525 L. Providers may not have the awareness or knowledge on process to query for and fill out the template M. Provider and patient may be burdened by the process of filling templates as part of the patient encounter N. Competing national CDE structure standardization initiatives O. Developing standardized CDEs for eClinical Templates 526 527 528 529 530 531 532 533 534 535 536 537 538 12.0 Dataset Requirements 539 540 541 542 Furthermore, it is important to understand that the identification of data elements forms the foundation for harmonization activities. The data elements identified in the Use Case set constraints on the contents of documents and messages. Workgroups should make every effort to ensure that the dataset and data element requirements are complete, accurate, and precise. 543 544 545 546 NOTE: This content of this section will vary per Initiative as the references are contingent upon the specific list of Functional Requirements that is developed by the Workgroup. The Use Case Simplification Workgroup is tasked with creating a structure for this section that will eventually be applied to all Use Cases. Data element sets are defined for reuse within the Use Case Simplification Workgroup 547 548 Suggested Format: Table, Bulleted Lists (including data element name, definition, example representation, and source vocabulary) Section Description: This table lists the data elements and data element sets that will be available within the message or document. Historically, the optional/required nature of each data element is deferred to the discussions during the harmonization phase. Since the experts who know what data are to be exchanged may be participating at this stage, it is essential that these dataset requirements be as fully specified as is possible. Each data element listed below is necessary for some aspect of the Use Case; however, the table does not specify exactly how they may be used together. All data element sets may contain multiple data elements unless otherwise stated. For the purposes of this section, do not assume that any data elements are inferred. Be sure to provide elements at their most granular level. For example, if it is necessary to specify a zip code, do not use the less specific data element set, ‘address’. In addition, specify the base standard from which they are chosen, i.e., a specific vocabulary (SNOMED), code set (gender, marital status), classification (ICD-10-CM), or other, and who maintains this terminology. 549 Section Data Element Multiple Values (yes/no) Data Element Description Vocabulary Additional Notes <<Bulleted list>> 3/22/2016 24 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 550 Table 7: Dataset Requirements 551 3/22/2016 25 Use Case Development and Functional Requirements for Interoperability DRAFT Structured Data Capture and FHIR for Electronic Determination of Coverage Use Case 552 553 554 555 Appendices 556 557 Appendix A: Related Use Cases 558 559 Appendix B: Previous Work Efforts 560 561 Appendix C: References The content of this section varies depending on the needs brought forth by the Community. Some Use Cases may have appendices that are specific to their content and issues. The appendices listed below are suggested for inclusion. <<Bulleted List>> <<Bulleted List>> <<Bulleted List>> 562 3/22/2016 26