Yes, there is a strong use case for exchange from payer to provider. The two use cases described in the Guidance introduction section are examples. For instance, the Guidance section says “The first interaction is when a Producer, such as a practitioner, or owner of data needs to exchange that data with a Consumer of that data, such as a payer, a registry or public health.” In this sentence, practitioner is just an example of Producer, payer could also serve as a Producer. Will update the General Guidance - Introduction section to make it clear that it is bi-directional, there is a use case from payer to provider.