Official website of the State of California
Official website of the State of California
No, using a QHIO is optional. Participants may choose to exchange HSSI via a QHIO, a nationwide network or framework, other intermediary, point-to-point connections using their own technology, or a combination of these methods to comply with the DSA and P&Ps. See related General DxF FAQs, notably questions 16, 30, and 31.
No, a nationwide network or framework, or Trusted Exchange Framework Qualified Health Information Network, is 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. However, as a signatory to the DSA, DxF Participants must ensure that the data sharing or other agreements they execute with any intermediary, including a nationwide network or framework, do not conflict with the DSA or its P&Ps in such a way that the Participant cannot meet DSA or P&P requirements.
CDII will assess any organization, including a Trusted Exchange Framework Qualified Health Information Network (QHIN) or nationwide network or framework if it applies to become a QHIO. Only organizations that apply for QHIO status during the open application period will be granted QHIO status. The QHIO application period may be offered by CDII annually, but not more often than once a year.
DxF Participants are not required to use a QHIO, and may use “any health information exchange network, health information organization, or technology that adheres to [DxF] standards and policies” as stated in HSC 130290(a)(2). According to the QHIO P&P, CDII will create a QHIO Program as an option that may help a Participant meet all of their DxF obligations. If a Participant chooses an option other than a QHIO, it is up to the Participant to ensure that the health information exchange network, health information organization, or technology they select adheres to DxF standards and policies
Participants may use “any health information exchange network, health information organization, or technology that adheres to [DxF] standards and policies” as stated in HSC 130290(a)(2). Nationwide networks and frameworks, including the Trusted Exchange Framework when it becomes operational, may be applicable to meet some or all exchange obligations under the DSA. CDII encourages DxF Participants to fully utilize the capabilities of exchange options already available to them or in use by them today.
Depending upon the Participant, a nationwide network or framework may not be able to meet all of a Participant’s obligations and the Participant may be required to supplement their use of a nationwide network or framework with other methods. It is the responsibility of the Participant to determine what obligations a nationwide network or framework can meet, how to ensure the Participant’s proper use of the network or framework to comply with the DSA and P&Ps (including but not limited to the Requirement to Exchange Health and Social Services Information P&P, the Permitted, Required, and Prohibited Purposes P&P, the California Information Blocking Prohibitions P&P, the Privacy Standards and Security Safeguards P&P, Data Elements to Be Exchanged P&P, Technical Requirements for Exchange P&P, and Real-Time Exchange P&P), and how to supplement the nationwide network or framework if required. See also the QHIO P&P, that states CDII will create a QHIO Program as an option that may help a Participant meet all of their DxF exchange obligations. QHIOs could be used to supplement participation in a nationwide network or framework when needed.
Yes. Health and Safety Code section 130290 does not differentiate between a “restricted health care service plan” and a “full service health care service plan.” Both a “restricted health care service plan” and a “full service health care service plan” are required to sign the DSA.