44. Can a QHIO include the names of Individuals requested by non-Participants on their rosters for requesting Notification of ADT Events? [7/18/2024]
The DSA and its P&Ps require that Hospitals and Emergency Departments, and optionally skilled nursing facilities, that are signatories to the DSA send Notification of ADT Events, via a QHIO if they choose, to any authorized organization that is a signatory to the DSA as requested via a roster of Individuals. The QHIO Program requires that QHIOs share rosters of Individuals with the other QHIOs to help facilitate Notification of ADT Events.
The DSA and its P&Ps do not prohibit a QHIO from including the names of Individuals requested by non-signatories on their rosters for Notification of ADT Events.
The DSA and its P&Ps do not prohibit QHIOs from sharing Notifications of ADT Events for Individuals requested by non-signatories, so long as the Disclosure complies with Applicable Law and relevant agreements. The DSA and its P&Ps likewise do not require that a signatory to the DSA send Notifications of ADT Events to non-Participants, whether or not the notifications are facilitated by a QHIO.