This document is about BCBSA and AHIP providing comments to the State All Payer Claims Databases Advisory Committee on the standardized reporting format and procedural guidance for voluntary reporting by group health plans to state APCDs, as required by the No Surprises Act. The comments focus on affirming the voluntary nature of reporting, establishing national industry standards for APCD data elements and exchange format, ensuring consumer privacy and data security protections, and providing opportunities for stakeholder review and comment prior to finalization of the recommendations.