While this IG is not covered under the ONC regulations and CMS Interoperability and Patient Access API regulations, it does sit within the landscape of IGs that do and so the following should be considered:

The ONC in line with the 21st Century Cures act and previous law has defined a set of standards and implementation guides that are required for its programs. The CMS Interoperability and Patient Access rule requires several of those standards and specifications. One of these requirements is FHIR US Core 3.1. 

The SVAP currently has adopting the new version (FHIR US Core 4.0.0), under consideration.

This means that until SVAP approves the use of the new standard, implementers may have a problem implementing this version of Plan Net. It should be discussed whether the movement to US Core 4.0 should be decoupled from the rest of the update in order to make those updates more readily implementable and move to US Core 4.0 when approved for regulatory use. This concern applies across all Da Vinci IGs covered under the same regulation.

Additionally, HRex, for which this IG bases its Practitioner, PractitionerRole, and Organization profiles on, currently uses US Core 3.1. This may cause confusion in the expectations/requirements.