Deadlines for signing the DxF DSA and beginning Exchange of Health and Social Services Information, as set forth in the Requirement to Exchange Health and Social Services Information Policy and Procedure and Health and Safety Code section 130290, subdivisions (b) and (f), are listed below.

 

Hospitals

Signatory Type3 Deadline to Sign the DSA Deadline to Begin Data Exchange
Rural general acute care hospitals with fewer than 100 beds January 31, 2023 January 31, 2026
Critical access hospitals January 31, 2023 January 31, 2026
Rehabilitation hospitals January 31, 2023 January 31, 2026
Long-term acute care hospitals January 31, 2023 January 31, 2026
Acute psychiatric hospitals January 31, 2023 January 31, 2026
All other general acute care hospitals January 31, 2023 January 31, 2024

 

[CLARIFIED] Physician organizations and medical groups

Signatory Type3 Deadline to Sign the DSA Deadline to Begin Data Exchange
Medical foundations exempt from
licensure pursuant to Health and Safety
Code section 1206(l)
July 1, 2026 July 1, 2026
Nonprofit clinics with fewer than 10 health
care providers
January 31, 2023 January 31, 2026
All other physician organizations and
medical groups
January 31, 2023 January 31, 2026
Skilled nursing facilities that Maintain
electronic health records
January 31, 2023 January 31, 2024
Health care service plans and disability
insurers
January 31, 2023 January 31, 2024
Clinical laboratories January 31, 2023 January 31, 2024
[NEW] Emergency medical services July 1, 2026 July 1, 2026
[NEW] Facilities operated by the
California Department of State Hospitals
or California Department of
Developmental Services which use
seclusion and behavioral restraints
January 31, 2023 January 31, 2029

 

3 Signatory types are simplified. For more information on the signatory types, please refer to question 1.

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Please see the EMS provider and LEMSA support FAQ for information about how EMS providers’ participation in the Data Exchange Framework (DxF) may be supported.

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Entities required to sign the DxF DSA, as set forth in Health and Safety Code section 130290(f), are listed below.

 

  • General Acute Care Hospitals, as defined by Health and Safety Code section 1250
  • [CLARIFIED] Physician Organizations and Medical Groups, which include:
  • Skilled Nursing Facilities (SNFs), as defined in Health and Safety Code section 1250, that Maintain electronic health records.
    • For purposes of this section, “electronic health records” means a System that contains an electronic record of health-related information on an Individual that is created, gathered, managed, and consulted by authorized health care clinicians and staff.
  • Health Plans, as follows:
    • Health Care Service Plans and Disability Insurers providing hospital, medical, or surgical coverage that are regulated by the California Department of Managed Health Care (DMHC) or the California Department of Insurance (CDI).
    • Medi-Cal Managed Care Plans that have signed a comprehensive risk contract with the Department of Health Care Services pursuant to the Medi-Cal Act1 or the Waxman-Duffy Prepaid Health Plan Act, 2 and that are not regulated by DMHC or CDI.
  • Clinical Laboratories, as described in Business and Professions Code Section 1265, and those that are regulated by the California Department of Public Health (CDPH)
    • Both registered laboratories and licensed laboratories that are regulated by CDPH are required to sign the DxF DSA.
  • Acute Psychiatric Hospitals, as defined in Health and Safety Code section 1250.
  • [NEW] Emergency Medical Services, as defined by Health and Safety Code section 1797.72.

 

[NEW] Beginning January 1, 2027, Department of Health Care Access and Information (HCAI) will publish and keep current on its website the names of any known entities it deems not to be in compliance with the requirement to execute the Data Exchange Framework (DxF) Data Sharing Agreement (DSA).

 

Entities that are encouraged, but not required, to sign the DxF DSA include:

 

  • Government public health and human services agencies, unless they otherwise are required to execute the DxF DSA by Health and Safety Code section 130290(f).
    • For example, a county-operated general acute care hospital which meets the definition of a general acute care hospital in Health and Safety Code section 1250 would be required to sign;
  • Social services organizations, including organizations providing housing services and nutrition assistance;
  • Specialized health plans that are not full-service plans, such as Employee Assistance Program (EAP) Plans;
  • Electronic health record (EHR) vendors;
  • Health information exchanges (HIEs) and other intermediaries, unless they have been qualified as a Qualified Health Information Organization (QHIO);
  • Non-physician health providers, so long as they are not otherwise part of a medical group practice, a professional medical corporation, or a medical partnership, including but not limited to:
    • Dentists;
    • Licensed clinical social workers;
    • Licensed marriage and family therapists;
    • Podiatrists
    • Psychologists
    • Registered nurses
    • Optometrists
    • Marriage and family therapists
    • Clinical social workers
    • Physician assistants
    • Chiropractors
    • Acupuncturists
    • Professional clinical counselors
    • Physical therapists
    • Pharmacists
    • Licensed midwives
    • Naturopathic doctors

 

1 Cal. Welfare and Institutions Code section 14000, et seq.
2 Cal. Welfare and Institutions Code section 14200, et seq.

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