The Data Exchange Framework (DxF) requires that every Participant provide Access to or Exchange Health and Social Services Information (HSSI) with every other Participant consistent with the Requirement to Exchange Health and Social Services Information
Policy and Procedure and the Permitted, Required and Prohibited Purposes Policy and Procedure. Information on DxF Participants can be found in the DxF Participant Directory Listing. If you have concerns about a Participant receiving HSSI, please contact DxF at DxF@hcai.ca.gov.
Note that Participants are still required to maintain the confidentiality of HSSI and cannot share HSSI if sharing would violate federal or state law. Refusing to share HSSI with another Participant because sharing would violate the law meets an exception to
Information Blocking in the California Information Blocking Prohibitions Policy and Procedure. For information on required Participants, see the required signatories FAQ. For technical requirements for data sharing, see the Data Elements to Be Exchanged Policy and Procedure, the Technical Requirements for Exchange Policy and Procedure, and the Real-Time Exchange Policy and Procedure which can be found on the Policies and Procedures section of the DxF website. For more information on privacy and security requirements and information blocking exceptions, please refer to the Privacy Standards and Security Safeguards Policy and Procedure and the California Information Blocking Prohibitions Policy and Procedure.
Participants must follow all applicable state and federal law when sharing Health and Social Services Information (HSSI) in accordance with the Data Exchange Framework Data Sharing Agreement. What laws apply during an Exchange may depend on the organization providing the HSSI, the organization receiving the information, the type of HSSI being Exchanged, the purpose for Exchange, and where the organization providing the HSSI obtained the information from. Please consult with your legal counsel to better understand what laws apply to the HSSI your organization is Exchanging. For more guidance on state and federal laws that affect Disclosure and sharing of health information, please see HCAI’s Data Exchange Framework Policies and Procedures, DHCS’ Data Sharing Authorization Guidance, and CalHHS’ State Health Information Guidance (SHIG).
When the DxF was first established under AB 133 (2021), the statute did not include enforcement or accountability mechanisms. Recently under SB 660 (2025), the legislature provided for some accountability measures, including public transparency, state purchasing levers, coordination with licensing entities, and contractual obligations among participants. SB 660 also directed the DxF Advisory Committee to evaluate and recommend potential future enforcement and dispute‑resolution approaches, ensuring that any additional authority is informed, deliberate, and appropriately resourced. More information on DxF Accountability Measures can be found on the Governance section of the DxF website.
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 DxF DSA.
[NEW] Yes, if you are required to sign the DxF DSA. Beginning July 1, 2026, unless already required by an existing contract requirement, signing the DxF DSA will be required as a condition of continuing, amending, or entering into a new or existing contract for the coverage of or provision of health care services with DHCS, CalPERS, and the California Health Benefit Exchange. DHCS, CalPERS, and California Health Benefit Exchange may require subcontractors and delegates to sign the DxF DSA as a condition of their contracts.