Incentive programs and improved data collection could help develop statewide health data exchange in California


Soraya Marashi


Last week, the California Health and Human Services Agency (CalHHS) released its long-awaited Data Exchange Framework, Data Sharing Agreement, and initial set of Policies and Procedures, pursuant to Assembly Bill 133’s requirements.

Along with the statutory requirement to release the Data Exchange Framework, Data Sharing Agreement, and Policies and Procedures by July 1st, the agency used guidance from the CalHHS Data Exchange Framework Stakeholder Advisory Group to release a set of policy recommendations for the state to use as a roadmap to implementing a robust and effective statewide health information exchange system. These include establishing incentive programs for health care organizations and strict standards for the collection and use of demographic and social determinants of health (SDOH) data. 

Some key recommendations are listed below.


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Establish an Electronic Health Record (EHR) incentive program

This incentive program would encourage adoption of certified EHR technology and clinical documentation technologies among health care organizations, as many health and human services organizations in California do not have the resources to invest in digital record systems that are necessary for the effective exchange of health information.

Establish a data exchange intermediary onboarding and technical assistance program

Many health and human service organizations will encounter technical, operational, and financial barriers to making connections with data exchange intermediaries. This program would provide funding, incentives, and technical assistance to help these organizations connect to a qualifying data exchange intermediary.

Expand on existing event notification requirements

Event notifications of changes to an individual’s condition (such as admission to, discharge from, or transfer to a health care facility) for an individual’s primary care practitioner or care team can be used to support care coordination and delivery. However, these notifications are often limited to a narrow set of participants and circumstances. CalHHS recommends that the state set policies to expand the scope of existing event notification requirements to include additional health and human services organizations and notification types.

Upgrade California county Health Information Technology (HIT) infrastructure

California’s health, public health, and human services agencies have varying capabilities to electronically exchange meaningful information with other health and human services organizations. CalHHS recommends that the state expand federally funded programs to upgrade state and local health, public health, and human service information technology infrastructure so that these entities can more easily participate in health information exchange. 

Establish demographic and SDOH data collection and use standards, requirements, and incentives

Standardized demographic and SDOH data in California remains inconsistent and oftentimes incomplete. CalHHS recommends that the state establish demographic and SDOH data standards, requirements, and incentives to encourage data collection, exchange, and use among health and human services organizations in California. CalHHS also recommends that the state improve demographic and SDOH data exchange between state agencies, as well as send recommendations to the federal government to improve national SDOH and demographic data exchange standards. 

Establish a provider directory and requirements for data reporting 

Robust provider information, such as name, practice locations, and organizational affiliates, is not always available or accessible to all health and human services organizations across the state. CalHHS recommends that the state establish a statewide provider directory and require signatories of the Data Sharing Agreement to contribute data to promote provider-to-provider communication and health information exchange. 

Establish policies to ensure individuals’ access to their longitudinal health information and policies to strengthen trust for individuals sharing data

Individuals oftentimes face challenges when trying to access their health and human services records in a convenient manner. CalHHS recommends that the state establish policies to ensure that individuals have timely and convenient access to their health care information across all health and human services organizations that are pursuant to the Data Sharing Agreement. Consistent access to this information will allow Californians to make informed decisions about their health care.  

Establish a ‘universal’ release-of-information authorization form, implement electronic consent management, and promote federal and state regulatory alignment

CalHHS recommends that the state establish a “universal” release-of-information authorization form to enable standardized data exchange, as well as an electronic consent management service that will allow individuals to digitally manage their consents to share their health and human services information. CalHHS also says that the state should make efforts to align federal and state information exchange requirements. 

Leverage governmental, private, and philanthropic sources of funding

Many health and human services organizations face significant financial barriers to making necessary health information exchange investments. CalHHS recommends that the state identify and pursue federal, state, private, and philanthropic funding opportunities to finance data exchange efforts, such as CMS Medicaid Enterprise Systems enhanced funding, CMS Medicaid matching funds, CMS Medicaid waivers, and state taxes.

CalHHS and the California Association of Counties are required to encourage as many county health, public health, and social services providers as possible to partake in the Data Exchange Framework by Jan. 31st, 2023. Numerous entities, including general acute care hospitals, physician organizations and medical groups, skilled nursing facilities, health service plans and disability insurers, Medi-Cal managed care plans, clinical laboratories, and acute psychiatric hospitals also will be required to execute the Data Sharing Agreement by Jan. 31st, 2023. 

The full implementation date is Jan. 31st, 2024, when, according to CalHHS, all participating entities will exchange health information or provide access to health information to and from every other entity in real time for treatment, payment, or health care operations.