38. Are Nationwide Networks or Frameworks, or Trusted Exchange Framework and Common Agreement (TEFCA) Qualified Health Information Networks (QHINs), required to sign the Data Exchange Framework (DxF) Data Sharing Agreement (DSA) for it to be used by a DxF Participant to meet Exchange obligations under the Data Sharing Agreement (DSA) or its Policies and Procedures (P&Ps)?
No, Nationwide Networks or Frameworks, including the TEFCA QHINs, are 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 under the DxF. However, as a signatory to the DxF DSA, DxF Participants must ensure that the data sharing or other agreements they execute with any Intermediary, including a Nationwide Networks or Frameworks or QHIN, do not conflict with the DxF DSA or its P&Ps in such a way that the Participant cannot meet DxF DSA or P&P requirements.