Comment:

This section illustrates the fundamental inconsistency of the provider attempting to provide supporting documentation to meet the payer's requirements, without actually knowing what those requirements are. Instead of persisting current state (all you're doing here is enabling less functional X12 278s), the payer or middleware layer should be able to query the provider's existing FHIR endpoints to ask for supporting documentation. Further, this would also enable the use of a RESTful Claim create instead of the custom operation. More importantly, it would actual enable the payer to dynamically receive supporting clinical documentation and would not increase provider burden.

Summary:

Architectural flaw