We would be concerned if the required signature means that the physician must select a null flavor if there isn't information to meet the data request. Would be valuable to see an example or use case where the EHR makes the attestation and how, if any, human involvement is required, as it is unclear if “EHR attesting” means a person needs to be involved. We are also not clear on what attesting to “fulfillment” means – does this mean the information was provided? Wouldn’t the payer receiving the information suffice – why is attestation needed?

Existing Wording:

Depending on the reason for the request, Payers may require signatures from EHRs attesting to the fulfillment of the data request. However, there has not been enough implementation experience with this to provide specific guidance on how this is done. We are seeking implementer feedback and comments on this issue

(Comment 6 - imported by: Jean Duteau)