CMS rules and other federal requirements were considered when drafting the DxF Policies and Procedures. In addition, the Department of Health Care Access and Information (HCAI) continues to monitor new and developing federal requirements for impact on the DxF.

Both Health and Safety Code section 130290 and the DxF Data Elements to Be Exchanged Policy and Procedure, which can be found on the Policies and Procedures section of the DxF website, require that health plans provide Access to or Exchange of claims, encounter, and clinical information that parallels the data required of plans by the CMS Interoperability and Patient Access Rule. Likewise, DxF requires that health care providers provide Access to or Exchange of the same data (that is, electronic health information (EHI)) that is required by the Federal Information Blocking Regulations, which is in turn already more than that required by the CMS Interoperability and Prior Authorization Final Rule.

However, both the CMS Interoperability and Patient Access Rule and the CMS Interoperability and Prior Authorization Final Rule focus on Fast Healthcare Interoperability Resources (FHIR) as the required transport, whereas the DxF Technical Requirements for
Exchange Policy and Procedure requires that all Participants support the same Integrating the Healthcare Enterprise (IHE) profiles found in eHealth Exchange, Carequality, and Trusted Exchange Framework and Common Agreement’s Qualified Health Information Network Technical Framework that are likely already available to many health systems. FHIR is optional, but encouraged, in the Technical Requirements for Exchange Policy and Procedure