Comment:

While it is a laudable goal to provide this use case a solution to continuity of care when switching between plans, it's important to recognize that the payers are under no obligation to accept a previous payer's determination of medical necessity or cover drugs/services/therapies in the same manner as the previous payer. The use case description should be very clear that this is about information exchange only and refrain from generalizing that such exchange will facilitate treatment continuity. A payer may receive information more quickly, but a human on the backend will still be making determinations about coverage.

Summary:

The use case description should be very clear that this is about information exchange only and refrain from generalizing that such exchange will facilitate treatment continuity.