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).

Comment:

The HIPAA requirement is supposed to be the initial format being sent by the physician. If all providers are utilizing FHIR, then utilizing the 275 as the HIPAA function does not make sense. Additionally, the existing wording makes it seem as though the 275 is included in HIPAA, which is incorrect. Should not lump the 275 in with the 278, as the 275 is not mandated under HIPAA

Summary:

The HIPAA requirement is supposed to be the initial format being sent by the physician.