For QRDA I, the effective time is the active time of the payer if I understand correctly. In the most current specification, the effective time has become mandatory, however no guidance has been given on what to do if this information is unavailable. This is especially important in situations where the code attribute for the value element for the payer is "9999" or unknown.

A similar question was asked previously about this (you can reference here: https://jira.oncprojectracking.org/browse/QRDA-201) and the solution was to set the effective time to the report start date when the effective time is unknown for the moment. Is this still the recommended solution for this problem?