Comment related to the following sentence "For EHRs that cannot support this protocol, the data will be stored on the payer server in a DocumentReference resource." Transient data should not be stored on the payer server. There is industry consensus that this is not an acceptable solution, the preferred solution would be to persist the data in the EHR. We have many patient safety and privacy concerns with this temporary measure, because ultimately nothing is stopping the payer from having access to PHI - even if the physician ultimately decides not to submit a request to the payer. The language here is insufficient. There must be stronger language that the payer must ignore the interim data until they receive a complete, finalized transmission. Security labels should be added here for added protection of the information. This section should also underscore the expectation that is EHRs eventually be able to store this data. Given this is an interim solution, and couched as an exception to the proper protocol, this IG should also point to best practices.