The DxF DSA and its P&Ps govern and require the Exchange of Health and Social Services Information under the DxF only among signatories to the DSA. Neither CDII nor the DxF prohibit Exchange among non-signatories or between signatories and nonsignatories, whether or not the exchange is facilitated by a QHIO. QHIOs and other Intermediaries assisting Participants to meet their DxF requirements should review their Business Associate Agreements (BAAs) and other agreements with their customers, as well as Applicable Law, in determining what Exchange they can facilitate among signatories and non-signatories to the DSA.

The DxF does not prohibit a QHIO who receives an ADT Event or Notification of an ADT Event from a DxF signatory from sharing any notification of the event with a nonsignatory, so long as the Exchange is permitted by Applicable Law, the DSA, the DxF P&Ps, and relevant BAAs or other agreements the QHIO has with its customers.