IPAs are required signatories to the DSA and, as Participants, are required to exchange the HSSI they maintain like any other Participant. If they host or manage an EHR or other system that maintains HSSI on behalf of their members, they are required to share HSSI with other Participants and may use any system or solution to exchange that information in accordance with the DSA and its Policies and Procedures. If a Participant does not maintain any HSSI, the Participant is not required to share HSSI under the DSA but must still follow any applicable Policies and Procedures, including but not limited to the DxF Requirement to Exchange Health and Social Services Information Policy and Procedure.