The guidance indicates that electronic notification will be required for any CHRIS or Provider system errors and network outages.  We find this language to be objectionable as it fails to recognize that in severe weather or other situations which result in network outages all means of electronic communication are typically unavailable.  This creates a burden on the provider to either travel to an area in which service is not down to notify DBHDS or receive a citation due to the inability to locate service.  We ask that DBHDS consider other alternatives to reporting that keep in mind the challenges associated with electronic communication during system and network outages.   

Furthermore, during the June CHRIS training session it was noted that the provider must provide proof of any network outages that render the provider unable to access the CHRIS system.  The guidance does not mention this requirement.  We are seeking clarification as to what information is expected when a provider notifies the IMU of any system outages or errors that prevent accessing of the CHRIS system in the guidance.  What is the timeline for providing proof of outage should that proof be required of the provider?