32. May a Qualified Health Information Organization (QHIO) require a Participant to sign agreements in addition to the Data Exchange Framework (DxF) Data Sharing Agreement (DSA)?
Yes, QHIOs may require Participants to sign additional agreements or contracts that specify the terms of the services they offer. In some cases, QHIOs may be acting as a Business Associate to a Participant as defined under HIPAA, requiring the parties to execute a Business Associate Agreement. Agreements that a Participant might be asked to execute by a QHIO include a participation agreement, a data sharing agreement distinct from the DxF DSA, and/or Business Associate Agreement.