The issue here is that CRD is invoked to determine if prior authorization is needed and, if so, what data needs to be sent. The data can't actually be sent to the payer and stored at this point in the workflow because the order hasn't been completed and no decision has been made to seek prior authorization. All we can do is provide the templates to the EHR for subsequent use - and the only way to do that with CRD is with a card. If you see alternative possible workflows, please suggest. Where there's no need for information to flow to a payer and the only requirement is that documentation exists in the EHR, agree there's no need to invoke DTR. We can explicitly add language noting that DTR should only be returned if the relevant information can't be found in the EHR and/or there's a need for data to flow to the payer. Will work out with ballot commenter a mutually acceptable solution Need to explore the option for a fully payer side PA where the only interaction with the provider is the initiation of the CDS request and a response with the PA number or a pended request that is completed via the PAS method for notification on PENDED PA requests.