Existing Wording: Optimally, the coverage decision exchange should allow relevant clinical information about decisions, treatments, and their context to align with the approach that clinicians and clinical systems take to describe this same content. This should and does include consideration of the Patient Care approach to longitudinal care planning and exchange and the regulatory framework of data exchange at transitions of care mandated by the Office of the National Coordinator for Health IT (ONC) and CMS.

Comment:

Given that this is a payor to payor exchange it must first respect the quality and nature of information which payors not clinicians have.

Suggest altering the wording to reflect that th payor way of representing information will be supported and where that information is available in a format conventional for clinicians that may be supported as well.

Summary:

Suggest altering the wording to reflect that the payor way of representing information will be supported