This was a hot topic as a result of ballot comment on the CDA Consolidation guide. The question was: Why is a procedures section or results section required if you have none. The suggestion was that this was required under Meaningful Use based on the requirments of thse suggestions in conformance tests from NIST. The conformance tests are to show that the document creator complies with the certification requirements, not that the instance meets the requirements of the stated standards and implementation guides. When in doubt, read the rules.
So, will every C32 sent under meaningful use have results and procedures? I would assert not. Will every certified product be able to produce those where they may be required? Yes.
That's the difference between a functionally valid EHR that produces C32 documents and a valid C32 instance.