Thank you for providing this rationale. As one of the former co-chairs of the SubPro PDP Working Group, I believe the rationale here is sound and makes sense especially in light of the IDN ePDP Phase 1 Recommendation. Though I am not sure
there are any rules or procedures necessarily governing this situation, I am of the view that because (i) the IDN ePDP was a “Recommendation” as opposed to the SubPro’s “Implementation Guidance” and (ii) the IDN ePDP Phase 1 occurred more recently, that the
IDN ePDP Phase 1 recommendation should be followed where, like here, there is a possible conflict.
Sincerely,
Jeffrey J. Neuman
Founder & CEO
JJN Solutions, LLC
+1.202.549.5079