The Centers for Medicare & Medicaid Services (CMS) rules, and other federal requirements, were considered when drafting the DxF P&Ps.

Both HSC § 130290 and the DxF Data Elements to Be Exchanged P&P require that health plans provide Access to or Exchange of claims, encounter, and clinical information that parallels the data required of plans by the CMS Interoperability and Patient Access Rule. Likewise, DxF requires that health care providers provide Access to or Exchange of the same data (that is, EHI) that is required by federal information blocking, which is in turn already more than that required by the CMS Interoperability and Prior Authorization Final Rule.

Further, the Data Elements to Be Exchanged P&P adopts the same definition of “Maintained” as found in the CMS Interoperability and Patient Access Rule. DxF does require the use of USCDI v2 rather than the USCDI version currently required by CMS rules and ONC.

However, both the CMS Interoperability and Patient Access Rule and the CMS Interoperability and Prior Authorization Final Rule focus on FHIR as the required transport, whereas the DxF Technical Requirements for Exchange P&P requires that all DxF Frequently Asked Questions 25 Last Updated: February 28, 2025 Participants support the same IHE profiles found in eHealth Exchange, Carequality, and TEFCA’s QHIN Technical Framework that are likely already available to many health systems. FHIR is optional, but encouraged, in the Technical Requirements for Exchange P&P.