Same response as  FHIR-36454 .  We're definitely not driving anyone to fax/email/portal.  They're already there.  The key thing is that moving to CRD does not require payers to change other aspects of their business.  Forcing them to change everything at once might result in no change at all.  CRD, DTR and PAS allow step-based changes that deliver real benefits but can still function with other existing processes.  This lowers the cost of change and makes incremental change possible that leads to eventual adoption of all 3.