This below sentence seems to be one taken from a PSS or IG proposal explaining what the IG will do rather than defining what the IGs scope is. Also I would shy away from saying that could possibly be construed as using ACS X12 intellectual property unless explicitly authorized.

Change:

"Since this IG describes a series of FHIR based use cases the use of X12 standards is not required. X12 will only be used to inform the PCT APIs. An implementer is not required to use X12 and there is no HIPAA mandate to do so."

To:

"This IG describes system interactions using the FHIR Standard. To use this guide there is no requirement to use NAIC administration/payment transmission standards, such as ASC X12, and there is no HIPAA mandate to do so for this use case. This however does not preclude the use of such standards in conjunction (e.g. a translating intermediary)"