CARIN Alliance Comments on ISA

The CARIN Alliance, a multi-sector group of stakeholders requests that ONC update the Health Care Claims or Equivalent Encounter Information for Professional Claims and Institutional Claims in the ISA to include the latest information related to the HL7® FHIR® Consumer Directed Payer Data Exchange (CARIN IG for Blue Button®) Implementation Guide (IG). Please see the attached comment letter for additional details.

CARIN Alliance Comments on ISA 093022_1.pdf

The use of standards based…

The use of standards based on 30 year-old UN-EDIFACT based standards needs consideration.  They work, but quite frankly, take a mountain of healthcare specific training to adopt. The payment industry needs to consider pilots for moving towards RESTFUL based APIs for payment based transactions across the board, in both batch and real-time formats.  It takes 5-10 years simply to adopt a new version of these standards to change the width of some fields and accommodate new coding or identifier systems 

CMS Response

CMS Response: We appreciate the feedback and look forward to receiving specific recommendations from industry for the use of alternative standards that enable the electronic exchange of health care information. The HIPAA regulations encourage pilots to test the use of alternative standards which meet the objectives of administrative simplification.