Participants may comply with the DxF by participating in and sharing information with a QHIO. However, just signing up to use a QHIO does not guarantee compliance with the DxF DSA and all of its P&P requirements. QHIOs offer access to critical services compliant with DxF technical standards requirements and have established critical connectivity that may help Participants comply with their obligations to provide Access to or Exchange of Health and Social Services Information (HSSI). It remains the responsibility of each Participant to ensure that they comply with requirements of the DxF DSA and its P&Ps beyond the technical standards enabled by using a QHIO by reviewing and complying with P&Ps including but not limited to: The Permitted, Required, and Prohibited Purposes Policy and Procedure for the purposes for which the Participant may and must share HSSI,

  • The Privacy Standards and Security Safeguards Policy and Procedure for information on privacy and security standards the Participant’s Systems must meet,
  • The Data Elements to Be Exchanged Policy and Procedure for information on data elements the Participant must make available,
  • The Technical Requirements for Exchange Policy and Procedure for the types of Exchange a Participant must enable, and
  • The Real-Time Exchange Policy and Procedure for information on the requirements for timely information sharing

All P&Ps listed above can be found on the Policies and Procedures section of the DxF website.

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Yes, QHIOs may require Participants to sign additional agreements or contracts that specify the terms of the services they offer. In some cases, QHIOs may be acting as a Business Associate to a Participant as defined under HIPAA, requiring the parties to execute a Business Associate Agreement. Agreements that a Participant might be asked to execute by a QHIO include a participation agreement, a data sharing agreement distinct from the DxF DSA, and/or Business Associate Agreement.

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Yes, QHIOs may charge for the services they provide to Participants. The Department of Health Care Access and Information recommends that Participants refer to the Policies and Procedures, including the Permitted, Required, and Prohibited Purposes Policy and Procedure and the Fees Policy and Procedure, both of which can be found on the Policies and Procedures section of the Data Exchange Framework website for more information on when Intermediaries, including QHIOs, may charge fees and restrictions on the fees they may charge. Please reach out to the QHIO(s) in which your organization is interested to learn more about the pricing of their services.

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No, QHIOs are not required by the Department of Health Care Access and Information or the QHIO Program to enter into contracts and serve every Participant that requests their services. Some QHIOs may not be able to meet the specialized needs of some Participants or the technologies they have chosen; may not be prepared to serve all Participant types; may not offer all of the services requested by a Participant beyond those required by Data Exchange Framework and the QHIO Program; or may not have the capacity to take on new Participants at the time of a Participant’s inquiry. Please reach out to the QHIO(s) your organization is interested in for more information on their ability to provide services to your organization.

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No, using a QHIO is optional. Participants may choose to Exchange HSSI through any health information exchange network, health information organization, or technology that adheres to the Data Sharing Agreement (DSA) and Policies and Procedures (P&Ps), which may be a QHIO, a Nationwide Network or Framework, other Intermediary, Point-toPoint Interface using their own technology, or a combination of these methods to comply with the DxF DSA and P&Ps.

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