34. Can a Participant require that a Qualified Health Information Organization (QHIO) guarantee the Participant will be in compliance with the Data Exchange Framework (DxF) if the Participant becomes a client of that QHIO?

In most cases, QHIOs are not able to guarantee Participants that use of a QHIO will ensure compliance with the DxF. While participating in and sharing information with a QHIO can help Participants to comply with the DxF, QHIOs may not have insight into a Participant’s internal policies and standard operating practices to determine whether the Participant was complying with the DxF Data Sharing Agreement (DSA) and all of its Policies and Procedures. Participants must assess their own processes and practices to ensure that they remain compliant in areas the QHIO is not responsible for. See Question 30 to better understand what areas are generally beyond the requirements of the QHIO Program. QHIOs may choose, but are not required by the Department of Health Care Access and Information, to offer services to assist or advise Participants in assessing their compliance with the DSA.