36. May a QHIO require a Participant to sign agreements in addition to the DSA? [12/11/2023]
Yes, QHIOs may require Participants to sign additional agreements or contracts that specify the terms of the services they offer. In some cases, QHIOs may be acting as a business associate to a Participant as defined under HIPAA requiring the parties to execute a business associate agreement. Agreements that a Participant might be asked to execute by a QHIO include a participation agreement, a data sharing agreement distinct from the DxF DSA, and/or business associate agreement.