Participants may use “any health information exchange network, health information organization, or technology that adheres to [DxF] standards and policies” as stated in HSC 130290(a)(2). Nationwide networks and frameworks, including the Trusted Exchange Framework when it becomes operational, may be applicable to meet some or all exchange obligations under the DSA. CDII encourages DxF Participants to fully utilize the capabilities of exchange options already available to them or in use by them today.

Depending upon the Participant, a nationwide network or framework may not be able to meet all of a Participant’s obligations and the Participant may be required to supplement their use of a nationwide network or framework with other methods. It is the responsibility of the Participant to determine what obligations a nationwide network or framework can meet, how to ensure the Participant’s proper use of the network or framework to comply with the DSA and P&Ps (including but not limited to the Requirement to Exchange Health and Social Services Information P&P, the Permitted, Required, and Prohibited Purposes P&P, the California Information Blocking Prohibitions P&P, the Privacy Standards and Security Safeguards P&P, Data Elements to Be Exchanged P&P, Technical Requirements for Exchange P&P, and Real-Time Exchange P&P), and how to supplement the nationwide network or framework if required. See also the QHIO P&P, that states CDII will create a QHIO Program as an option that may help a Participant meet all of their DxF exchange obligations. QHIOs could be used to supplement participation in a nationwide network or framework when needed.