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EDMUND G. BROWN JR.
Governor

State of California—Health and Human Services Agency
California Department of Public Health


AFL 23-23
June 30, 2023


TO:
General Acute Care Hospitals (GACHs)
Acute Psychiatric Hospitals (APHs)
Skilled Nursing Facilities (SNFs)

SUBJECT:
California Health and Human Services (CalHHS) Data Exchange Framework (DxF)



​All Facilities Letter (AFL) Summary​

This AFL notifies GACHs, APHs, and SNFs that maintain electronic records of their obligation to exchange or provide access to health information in real time pursuant to the CalHHS DxF data sharing agreement for treatment, payment, or health care operations on or before January 31, 2024, except for certain specified facilities that must meet this requirement by January 31, 2026.

​​AB 133 (Chapter 143, Statutes of 2021) added HSC section 130290 establishing the CalHHS DxF. The DxF includes a single data sharing agreement and common set of policies and procedures that will leverage and advance national standards for information exchange and data content by requiring the real-time exchange of health information among health care entities and government agencies in California.

The entities specified by CalHHS that must participate in the DxF include the following:

  • GACHs;
  • APHs;
  • SNFs that currently maintain electronic records;
  • Physician organizations and medical groups;
  • Health care service plans and disability insurers that provide hospital, medical, or surgical coverage that are regulated by the Department of Managed Health Care or the Department of Insurance;
  • Medi-Cal managed care plans under a comprehensive risk contract with the State Department of Health Care Services that are not regulated by the Department of Managed Health Care or the Department of Insurance; and
  • Clinical laboratories that are regulated by CDPH.

The DxF aligns with state and federal data requirements, including the federal Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191), the Confidentiality of Medical Information Act of 1996 (Part 2.6 (commencing with Section 56) of Division 1 of the Civil Code), and other applicable state and federal privacy laws related to the sharing of data among and between providers, payers, and the government, while also streamlining and reducing reporting burden. For the purposes of the DxF, “health information" includes all electronic health information as defined under federal regulation in Section 171.102 of Title 45 of the Code of Federal Regulations and held by the entity. 

Pursuant to AB 133, all GACHs, APHs, and SNFs that currently maintain electronic records, should have signed and executed the DxF data sharing agreement in alignment with existing federal standards and policies on or before January 31, 2023.

On or before January 31, 2024, GACHs, APHs, and SNFs that currently maintain electronic records, must exchange health information or provide access to health information to and from every other entity specified by CalHHS pursuant to the DxF data sharing agreement for treatment, payment, or health care operations. However, rehabilitation hospitals, long-term acute care hospitals, APHs, critical access hospitals, and rural GACHs with fewer than 100 acute care beds, as well as state-run APHs, do not need to meet this requirement until January 31, 2026.

CDPH's failure to expressly notify facilities of statutory or regulatory requirements does not relieve facilities of their responsibility for following all laws and regulations. Facilities should refer to the full text of all applicable sections of the Health and Safety Code and the California Code of Regulations to ensure compliance.

If you have any questions or concerns about the requirements of the DxF, please contact the Center for Data Insights and Innovation at cdii@chhs.ca.gov.

 

Sincerely,

Original signed by Cassie Dunham

Cassie Dunham

Deputy Director

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