Existing Wording: The CMS NPRM on interoperability published in the Federal Register on March 3, 2019, requires that providers enable members to exchange clinical information from a prior payer to the current payer for a period of 5 years after they leave a plan and move to another covered plan.

Comment:

The term provider here should be switched to "payer". This guide appears to be applying to health plans sharing information from one plan to the next, so a typical healthcare "provider" would not be involved.

Summary:

The term provider here should be switched to "payer".