Home Framework Intrepid Ascent Says CalHHS Data Sharing Framework Should Be More Specific About Qualified Intermediary Criteria for Data Sharing – Status of Reform

Intrepid Ascent Says CalHHS Data Sharing Framework Should Be More Specific About Qualified Intermediary Criteria for Data Sharing – Status of Reform


With the release of CalHHS Data Exchange Framework (DxF), Data Sharing Agreement, and Initial Set of Policies and Procedures July 5, stakeholders across the state are praising the ability of new developments to dramatically improve data sharing in California.

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Intrepid Ascent, a state health care consulting group, highlighted the state’s progress toward ubiquitous data exchange in California.

“As an industry, we have 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 HIE’s value proposition – the past few years have shown the potential for real and lasting change in both individual outcomes and system improvement through HIE’s comprehensive care program. state, which in many ways laid the foundation for the DxF.

The organization also voiced criticism of CalHHS’ initial set. Policies and Procedures. They said the initial set is adequate considering the acceleration timeline the stakeholder advisory group under which was working, there are significant gaps that may prevent or slow institutions from signing the DxF.

“The most notable gap is a clear definition of a Qualified Intermediary for data sharing and processes on how the state will ‘certify’ Qualified Intermediaries (or HIO Qualified Health Information Organizations ) if the state adopts this nomenclature),” the organization said. “A number of regional HIOs are fully operational in California and it is unclear what role these entities will play, especially since they all have their own local rules, agreements and policies.”

In Intrepid Ascent publication for the California Health Care Foundation titled “Designing an Effective Statewide Data Sharing Agreement”, they discuss how improving data sharing across the state will benefit the health care system, indicating how consolidating laws and Federal and state health privacy regulations will allow for more efficient sharing of data between public health facilities.

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

Many data-sharing agreements lack key stakeholders – such as rural providers, health plans, community organizations, and state and county and behavioral health entities – and lack important types of data ; for example, the social determinants of health information.

Intrepid Ascent also highlighted how the DxF extends the state’s already stringent policies to protect sensitive consumer information.

“In light of recent political developments at the federal and state level, protecting the privacy of individuals is more essential than ever. California already has some of the strongest privacy laws in the country, in addition to the federal protections of 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 permitted and only what is necessary to provide care and services to the individual and adopts HIPAA privacy and security rules as its basis of protection, including for entities not otherwise covered by HIPAA, such as community organizations. »

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

They also identified alignment between DxF policies and processes and local or national provider-based networks as a key implementation challenge.