Intrepid Ascent says CalHHS Data Exchange Framework should be more specific about criteria for qualified data-sharing intermediaries


Soraya Marashi


With the release of CalHHS’s Data Exchange Framework (DxF), Data Sharing Agreement, and initial set of Policies & Procedures on July 5th, stakeholders across the state are lauding the new developments’ ability to significantly improve data sharing in California.


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Intrepid Ascent, a health care consulting group in the state, highlighted the progress the state has made toward ubiquitizing data exchange in California.

“As an industry, we’ve long understood the opportunity for Health Information Exchange (HIE) but the state has struggled to make widespread progress,” Intrepid Ascent said. “We are past the point of establishing the value proposition of HIE—the past several years have shown the potential for real and lasting change in both individual outcomes and system improvement through the state’s Whole Person Care program, which in many ways laid the groundwork for the DxF.”

The organization also provided some criticism about the initial set of CalHHS’ Policies & Procedures. They said though the initial set is adequate considering the accelerated timeline the Stakeholder Advisory Group was working under, there are significant gaps that may hinder or slow institutions from signing on to the DxF.

“The most notable gap is a clear definition of a qualified data-sharing intermediary and processes for how the state will ‘certify’ qualified intermediaries,” the organization said. “A number of regional HIOs are fully operational in California and it is unclear the role that those entities will play, especially since they all have their own local rules, agreements, and policies.”

In Intrepid Ascent’s publication for the California Health Care Foundation titled “Designing an Effective Statewide Data Sharing Agreement,” they discuss how improved data sharing across the state will benefit the health care system, stating how the consolidation of federal and state health privacy laws and regulations will allow for more efficient data sharing between state health care institutions.

“This framework will enable and require real-time access to and exchange of health information among providers and payers directly between each other and through qualified data exchange networks,” the publication said. “Currently, data exchange in California takes place under a patchwork of voluntary data sharing agreements established by state and national networks, as well as under a multitude of community and program-specific agreements.

Many data exchange arrangements are missing key stakeholders  — such as rural providers, health plans, community-based organizations, and behavioral health and state and county-based entities — and missing important types of data; for example, social determinants of health information.”

Intrepid Ascent also highlighted how the DxF expands on the state’s already stringent policies to protect consumers’ sensitive information. 

“In light of recent policy developments at the federal and state level, protecting individual privacy is more critical than ever. California already has some of the most stringent privacy laws in the country, on top of federal protections in HIPAA and 42 CFR Part 2—all of which are covered by the DxF. The DxF limits the use and disclosure of individual data to what is legally allowed and only what is needed to provide care and services to the individual and adopts the HIPAA Privacy and Security Rules as the floor of protections, including for those entities not otherwise covered by HIPAA such as community-based organizations.”

With implementation of the DxF, Intrepid Ascent said they are expecting varying levels of readiness for meaningful participation among mandated participants, in terms of technology, policy, and human infrastructure.

They also identified the alignment between the policies and processes of the DxF and local networks or national vendor-based networks as a major challenge of implementation.