Existing Wording: The IG uses the FHIR standard as the basis for assembling the information necessary to substantiate the need for a particular treatment and submitting that information and the request for prior authorization to an intermediary end point. That endpoint is responsible for ensuring that any HIPAA requirements are met (see above).

Proposed Wording: That endpoint is responsible for ensuring that any HIPAA Transaction and Code Set requirements are met (see above).

Comment:

Need to clarify because there are HIPAA Privacy and Security requirements that the disclosing provider must meet that are a separate concern, which this and associated DaVinci IGs need to address as well as Transaction and Codes Set standards.

Happily, this IG does discuss the interrelationship in the Administrative Simplification Requirements of HIPAA section. Recommend that where the discussion is focused on compliance, that the specific HIPAA regulation be called out.

Summary:

Need to clarify because there are HIPAA Privacy and Security requirements that the disclosing provider must meet