16. The DSA requires entities to meet the obligations set forth in the P&Ps, but how can I be sure that our organization can fulfill our obligations under the DSA if the P&Ps aren’t finalized yet?
Many health care entities are required by law to sign the Data Sharing Agreement (DSA) by January 31, 2023, with most to begin exchanging data in accordance with the DSA’s policies and procedures (P&Ps) by January 31, 2024. Signing the DSA is the first step in a yearlong process to fully implement the DxF by January 31, 2024 for most entities. Some entities, including physician practices with fewer than 25 physicians, acute psychiatric hospitals, and rural general acute care hospitals, will have until January 31, 2026 to fully implement the DxF. In 2024, entities that have signed the DSA can comply with the P&Ps either by joining and utilizing an intermediary, such as a Qualified Health Information Organization (QHIO), or by independently meeting the requirements of the P&Ps. To assist in this process, entities that sign the DSA may be eligible to receive grant funding to help them connect to a QHIO through the QHIO Onboarding Grant or to otherwise help them identify and implement solutions to meet the DxF requirements with the Technical Assistance Grant.
The P&Ps have been under development since early 2022 and continue to be developed in 2023, through a public and collaborative process that is designed to take into account the needs of all health and human services providers, the individuals they serve, as well as consumers. The P&Ps that have already been finalized and adopted are available here. Additional P&Ps are being released on an ongoing basis for public comment and have been reviewed and discussed in public DSA P&P Subcommittee meetings. Also, CalHHS and CDII are holding public webinars, town halls, and Implementation Advisory Committee (IAC) meetings in order to provide updates, answer questions, and garner feedback regarding DxF implementation. Most P&Ps will become effective January 31, 2024.
We urge stakeholders, organizations, advocates, and consumers to join these public meetings to ask questions and offer feedback. This is an open, transparent process to inform providers of their obligations under the DSA. CalHHS and CDII are working to ensure a smooth transition and adoption of the DxF, and we encourage you to reach out to any of our Educational Initiative Grantees for additional and industry-specific assistance meeting your obligation to sign the Data Sharing Agreement:
View Educational Initiative Grantees, contact, website, and signatory types table in the DxF FAQ PDF.
You can also reach out to CDII directly at cdii@chhs.ca.gov.