The Procedure Activity Observation and Procedure Activity Procedure templates are unusually restrictive in limiting the cardinality of the performer/representedOrganization/telecom to [1..1]. As far as I've found, they're the only two templates in C-CDA that do this; most other mentions of a representedOrganization don't specify a cardinality for the telecom element at all or else allow [1..*].

This makes it impossible to specify, say, an organization's phone number and its fax number. Should the cardinalities here be loosened to [1..*] as well? (And if so, is it a design change or an errata?)

Procedure Activity Observation: The representedOrganization, if present, SHALL contain exactly one [1..1] telecom (CONF:1098-8260).

Procedure Activity Procedure: The representedOrganization, if present, SHALL contain exactly one [1..1] telecom (CONF:1098-7737).