Data Exchange Framework Stakeholder Advisory Group Meeting #7

Different views on Data Exchange Framework (DxF) governance…

In the most recent DxF Stakeholder Advisory Group meeting earlier this month, members of the DxF Stakeholder Advisory Group discussed California Health and Human Services Agency’s (CalHHS) proposal to delegate DxF oversight, enforcement, and/or rulemaking authority to a separately appointed “HIE Policy Board” that would not include affected organizations.

While agreeing that governance is important, Advisory Group members were concerned that it is too early to select a governance model as the items that will be “governed”—the data sharing agreement and policies—have not yet been defined.

Advisory Group members also shared that “governmental” authorities such as regulation and enforcement should be retained within government and voiced concerns about excluding affected organizations from the governance body:

If you have a [Policy Board] that’s very mission aligned but doesn’t understand the context and the actual obligations, we have a high likelihood of ending up with something that’s very unworkable…I would recommend keeping the regulatory authority in the government [and] having [an advisory] group that includes those that are regulated.”

— Claudia Williams, Chief Executive Officer, Manifest MedEx

…and positive news from state officials on urgent priorities

We were pleased to see CalHHS revise its presentation materials from the last meeting to “integrate the concept that providers can meet their obligations under the DxF by connecting to a Qualified Data Exchange Intermediary.” MX has consistently stated that leveraging qualified intermediaries is the only realistic way for the thousands of health care entities in California to verifiably execute the DxF.

Another welcome development was CalHHS’s explicit recognition of a key common ingredient to data-sharing successes in New York, Maryland, and Michigan:

All three states heavily leverage federal funding through departments of health (Medicaid) to support and expand HIE capabilities, and leverage health department roles to align HIE participation incentives.”

CalHHS DxF Meeting #7 Presentation, Slide 25

Federal funding for HIE infrastructure and provider data sharing incentives are precisely the goals of the $95 million Data Sharing EQUITY budget proposal that MX is advocating for, along with more than 20 other HIEs, health plans, and provider organizations.

Lastly, MX was encouraged to learn that a draft of the Data Sharing Agreement (DSA) will be discussed at the April 26th Subcommittee meeting. MX will be reviewing it as soon as it is out and providing our comments to CalHHS.

The Advisory Group next convenes on May 18, which is shortly after the May Revision to the Governor’s Budget. We are hoping the budget includes much needed funding for HIE infrastructure and provider data sharing incentives.

We invite you to follow @ManifestMedEx on Twitter for live tweets, share your thoughts with us at, and stay tuned for more updates!

For a recap of past meetings, please check out News and Perspectives on our website.