Data Exchange Framework Stakeholder Advisory Group Meeting #9

The Data Exchange Framework (DxF) Stakeholder Advisory Group closed with its last meeting on June 23. The California Health and Human Services Agency (CalHHS) team previewed its final changes to the DxF, Data Sharing Agreement (DSA), and initial policies and procedures (P&Ps). These incorporate the Agency’s review of public comments on the latest draft documents before publishing the final versions on July 1.   

At the culmination of this nine-month process, Manifest MedEx echoes the reflections of CalHHS Secretary Dr. Mark Ghaly, Chair of the Advisory Group: 

“I am really proud of how this work has put the person back in the center… as [everyday Californians] seek to improve their lives, at some of their most vulnerable moments.” 

Compared to where discussions on the DxF began last fall, we simultaneously see significant improvements, crucial commitments for next steps, and substantial remaining gaps. 

Important progress and next steps 

CalHHS has made the important decision to include a definition for Qualified HIOs in the latest DSA draft. In a state as vast and complex as ours, this is the only viable path to near-universal data sharing—a finite and vetted set of networks for health care and social service organizations to partner with in fulfilling the DSA. MX was pleased to learn that over the next six months, CalHHS will prioritize, as part of the next batch of P&Ps, a Qualified HIO state designation process.  

Another critical element raised by various Advisory Group members and stakeholders is what real-time data exchange will mean in practice for requestors and recipients of health information. This, too, has been slated for P&P development through the rest of the year. 

With Secretary Ghaly’s recent emphasis that CalHHS has no plans to extend the statutory timeline for implementation, we urge CalHHS and partners to have all of the above P&Ps in place by the January 2023 DxF launch: 

“If signing [the DSA] includes selecting a Qualified HIO I also question the whole sequence because we haven’t defined what those are yet…that just doesn’t feel feasible to complete by January.” 

— Claudia Williams, CEO, Manifest MedEx 

Remaining gaps in policy… 

Some Advisory Group members voiced concerns about the absence of a mandate to proactively share certain data without prompting or requests, e.g., ADT feeds from hospital participants. 

“In my mind, exchange is both push and pull…I don’t see anything about initiating data exchange. Why aren’t we talking about exchange in general?”  

— Mark Savage, Director, Savage & Savage LLC  

CalHHS responded they will consider this “duty to initiate” in future discussions. MX recommends the Agency go further by formally adopting proactive sharing requirements as part of the DSA P&Ps. 

…and infrastructure investments 

The state has taken great strides to acknowledge Qualified HIOs as the backbone for many DxF participants’ data sharing capabilities. Now, it must fill the void of ongoing funding for this critical infrastructure to succeed. The need was well-stated by an HIO member of the Data Sharing EQUITY coalition: 

“The state’s expecting a lot from the HIOs, and we’re ready to take on that challenge, but there needs to be funding for maintaining this infrastructure. Other states are doing similar things. This hard work needs to be backed by direct funding.”  

— Ali Modaressi, CEO, Los Angeles Network for Enhanced Services (LANES) 

In the coming days, CalHHS will release not only the official DxF/DSA and initial P&Ps, but also plans to convene an interim Implementation Advisory Committee and DSA P&P Subcommittee. MX is excited to dive into the completed data-sharing policies and will continue sharing our expertise and perspectives with the state. 

We encourage you to follow our review of the final DxF documents as well as the road to implementation. For a recap of past meetings, please check out News and Perspectives on our website.