DxF Initiative

CalHHS and AAPCA1

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DxF

• Create equitable and affordable health information exchange.
• Patients, providers, and other healthcare entities can access the health information they need, wherever they are and whenever they need it.

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•  The CalHHS Health and Human Services Data Exchange Framework (DxF).

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• Single Data Sharing Agreement (DSA) and common set of Policies and Procedures (P&Ps) that will govern the exchange of health and social services information among health care entities and government agencies beginning January 31, 2024. 

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• DxF DSA Signing Portal is now open for providers and healthcare entities.
• DSA is a signed agreement between hospitals, physician organizations and medical groups, skilled nursing facilities, health plans and disability insurers, clinical laboratories, and acute psychiatric hospitals to share patient information safely.
• California Health and Safety code requires most providers and healthcare entities to sign the DSA by January 31, 2023.

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• Finalized on July 1, 2022.
• DxF was developed with input from a broad set of stakeholders, including a Stakeholder Advisory Group as required by AB 133. 
• The legislation mandates that a broad spectrum of health care organizations execute the Framework’s DSA by January 31, 2023, and exchange or provide access to health information with other mandated organizations by January 31, 2024. 

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Who is required to sign the Data Exchange Framework (DxF) Data Sharing Agreement (DSA) on or before January 31, 2023? 

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• General Acute Care Hospitals, as defined by Health and Safety Code Section 1250. 
•  Physician Organizations (e.g., Independent Practice Associations that exchange health information) and Medical Groups. 
• Skilled Nursing Facilities, as defined in Health and Safety Code Section 1250. 
• Health Plans 
• Clinical Laboratories, as defined in Business and Professions Code Section 1265 and that are licensed by the California Department of Public Health. 
• Acute Psychiatric Hospitals, as defined in Health and Safety Code Section 1250 

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Are all mandatory signatories required to sign the DSA by January 31, 2023, including those identified in AB 133 who are not required to exchange data under AB 133 until January 31, 2026? 

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• Under AB 133, all mandatory signatories must sign the DSA by January 31, 2023. Some of these organizations, such as smaller physician practices and clinics, rehabilitation, long-term acute care, psychiatric, and critical access hospitals, and smaller rural acute care hospitals, will have until January 31, 2026 to fully implement the Data Exchange Framework even though they signed the agreement in January 2023. 

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                       Obligations of DSA

• After signing, DxF DSA signatories will be required to exchange health and social services information or provide access to health information to and from every other signatory in real time as specified in the DSA and its Policies and Procedures (P&Ps). 

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• Most entities required to sign the DSA will be required to begin exchanging health and social services information on or before January 31, 2024. 

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• Some organizations will have until January 31, 2026 to begin exchanging this information. 

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• These organizations are as follows:

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• Physician practices of fewer than 25 physicians, rehabilitation hospitals, long-term acute care hospitals, acute psychiatric hospitals, critical access hospitals, and rural general acute care hospitals with fewer than 100 acute care beds, state-run acute psychiatric hospitals, and any nonprofit clinic with fewer than 10 health care providers. 

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• CalHHS is working on establishing a program to qualify eligible health information organizations (HIOs) to facilitate data exchange between signatories. More information on the program will be available soon. 

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Once I sign the DSA, what laws do I have to follow in order to share information with another Participant? 

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• Participants must follow all applicable state and federal law when sharing Health and Social Services Information through the DSA. 

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• For example, if the information is covered by the Health Insurance Portability and Accountability Act (HIPAA) and the Lanterman-Petris-Short Act (LPS), the Participant would need to meet an exception in both HIPAA and LPS in order to share the information. 

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• In addition, health information can generally be shared with a valid authorization for release of information from the patient/individual. 

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• For more information on how to share some types of health information in California, please see CDII’s State Health Information Guidance (SHIG). 

How are signatories to the Data Sharing Agreement (DSA) supposed to share data? 

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• Participants will provide access to or exchange information including through any health information exchange network, health information organization, or technology that adheres to the DSA and Policies and Procedures found on our web site at Data Sharing Agreement and Policies & Procedures. 

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• The DxF is not intended to be an information technology system or single repository of data, rather it is a collection of organizations that are required to share health information using national standards and a common set of policies. 

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Who are signatories to the Data Sharing Agreement required to share data with? 

• The Data Exchange Framework requires:
• Participant provide access to or exchange health and social services information with every other Participant consistent with the Permitted, Required and Prohibited Purposes Policy and Procedure.
• Participants are not required to share health and social services information if sharing would violate federal or state law. 

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Data Exchange Framework�

Seth Bokser, MD, MPH FAAP

• Federal Requirements
• CA Policies and Procedures
• Pediatrics Considerations and Feedback

California Consistent with Federal Regulation for Expanding Health Data Exchange

= National TEFCA

= California DxF

https://www.chhs.ca.gov/data-exchange-framework/

https://www.healthit.gov/isa/taxonomy/term/676/uscdi-v2

Pediatric Use Cases

1. Guardians inappropriately getting access to private or protected adolescent data

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• Children inappropriately gaining access to private or protected maternal health data

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• Guardians sharing children’s health data broadly before the children are of the age to control their own data

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• Patients or guardians providing data to a third-party app that gets compromised or inappropriately shares data, or adolescents sharing their own data without fully understanding the lifelong implications.

Data Blocking = When entity interferes with access, exchange, or use of electronic health information

2 Exceptions

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• Psychotherapy notes that are separated from the rest of the individual’s medical record. 

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• Information compiled in reasonable anticipation of, or use in a civil, criminal or administrative action or proceeding.

Questions, Comments, Discussion

Digital Identities and Patient Matching

Data Blocking = When entity interferes with access, exchange, or use of electronic health information

2 Exceptions

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• Psychotherapy notes that are separated from the rest of the individual’s medical record. 

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• Information compiled in reasonable anticipation of, or use in a civil, criminal or administrative action or proceeding.