Existing Wording: In either event, if the response is provided via X12, the intermediary will convert the X12 back to FHIR and will return the result as the result of the synchronous operation .

Comment:

If the X12 process is required in order to enable health plans to process the provider data, then the clearinghouse/vendor should be a business associate of the plan. This solution is proposing that a provider hire a business associate to translate information so that plans systems can handle. In other words, the process is requiring a provider to initiate PA with something other than the standard, which would mean that the proposed solution would cause them to improperly bear the cost of translating to be HIPAA compliant

Summary:

This solution is proposing that a provider hire a business associate to translate information so that plans systems can handle.