Removal of the 278 ceiling would solve this issue. However, the IG is silent on how we move from the HIPAA required Prior Authorization and Notification Inquiry (278) transaction to the FHIR based approach. (Response): The way to remove the 278 ceiling is via legislation which the requestor is used to pursue. The ability to remove the requirement for the 278 short of legislation is not available. Determinations are expected to be made within 15 seconds. The 15 seconds is represented in a specification diagram, but not a written service level agreement. Further, as currently architected, the provider Health IT system is in the critical path of the response time and creating an SLA for multi-party transactions is difficult. (Response): The 15 second requirement is for compliance with this implementation guide is not an SLA that may be created between trading partners. Pended Status checking can be done either by Polling or Subscription, neither of which have a linked IG. (Response): Poling does not have an Implementation Guide. There is an Implementation Guide for subscription, and we do include a link in section 5.2.4.2. Process enablers such as ability to update or cancel the prior authorization have not been fully addressed. (Response): Details around cancelling and modify are in Section 5.2.6