Existing Wording: Discussion with EHR implementers has suggested that a FHIR-based process for submitting prior authorization requests would have significantly higher uptake. This implementation guide attempts to do that while still retaining compliance with HIPPA requirements.

Comment:

The HIPAA transactions were originally deployed in the late '90s. Technology capabilities have progressed and CMS now supports API solutions (for example BlueButton). Instead of providing only a FHIR to X12 mapping solution, can you approach CMS to request they permit FHIR to FHIR transactions as an alternative standard for the 278 and 275 transactions between provider and payer. If both sender/receiver can support FHIR, it is a burden to require senders/receivers to implement both (X12 and FHIR solutions) plus implement mappings between FHIR and X12.

Summary:

Can you approach CMS to request they permit FHIR to FHIR transactions as an alternative standard for the 278 and 275 transactions between provider and payer.