USCDI 3 defines Coverage Status as "Presence or absence of health care insurance."  While it is clear how to assert when a patient generally or a specific service or encounter has coverage, it is unclear how to assert that the patient has no coverage overall or for particular encounters or services.  Absence of a Coverage resource instance or lack of a reference is not enough.

We propose that the definition of Coverage.type is updated with a comment to statement something like "Note that the absence of a Coverage resource instance or a reference to a Coverage resource instance does not mean that the patient has not coverage at all or for one or more specific services or encounters.  The coverage available may just not have been documented yet or not (yet) known to the healthcare provider.  Rather, the use of a self pay payer type will indicate whether the patient has no coverage for some or no services at all."