32. Are nationwide networks or frameworks, or TEFCA QHINs, required to sign the Data Exchange Framework Data Sharing Agreement for it to be used by a DxF Participant to meet exchange obligations under the Data Sharing Agreement or its Policies and Procedures? [9/1/2023]
No, a nationwide network or framework, or Trusted Exchange Framework Qualified Health Information Network, is not required to sign the DxF DSA in order to be used by a DxF Participant to meet some or all of its exchange obligations. However, as a signatory to the DSA, DxF Participants must ensure that the data sharing or other agreements they execute with any intermediary, including a nationwide network or framework, do not conflict with the DSA or its P&Ps in such a way that the Participant cannot meet DSA or P&P requirements.