Existing Wording: The intermediary SHOULD execute a 278i response t o return the status. However, if the payer does not support that function, the intermediary SHALL return the most recent copy of the prior authorization response as received from the payer. (Note that in this latter case, the intermediary would need to persist prior authorization information and would therefore be a 'covered entity' for HIPAA purposes.)

Comment:

If we are going to reference the 278i, it needs to be defined somewhere in this guide. Included in such defintiion should be an indication that this is NOT a HIPAA-mandated transaction. Also, should the IG mention earlier that the provider system is sending the 278i inquiry first? This appears out of nowhere.

Summary:

If we are going to reference the 278i, it needs to be defined somewhere in this guide.