Calif. Law Creates Pathway for Data Exchange Framework Enforcement

California Gov. Gavin Newsom has signed a bill into law that builds an accountability framework around the state’s ambitious Data Exchange Framework (DxF).

California is establishing the DxF to improve how health information is shared across the health and social services systems. Among the goals are protecting public health, improving care delivery, and guiding policies aimed at caring for the whole person, while maintaining patient privacy, data security, and promoting equity.

The Framework includes a single data-sharing agreement and a common set of policies and procedures that required the exchange of health information among large healthcare entities and government agencies by Jan. 31, 2024. (Smaller provider organizations have until 2026 to comply.)

The California Health & Human Services Agency (CalHHS) has named nine entities as Qualified Health Information Organizations, which are expected to play a key role in the success of the DxF, filling gaps in California’s data exchange infrastructure by facilitating connections between participants through the secure exchange of health and social services information.

The recently signed SB 660 legislation introduced by Senate Health Committee Chair, Caroline Menjivar, reinforces accountability and participation in DxF. It clarifies which providers must comply with the DxF, requires the California Department of Health Care Access and Information (HCAI) to report on participation, and creates a pathway for enforcement to ensure consistent adherence to the law.

“Governor Newsom’s signature on SB 660 sends a strong message: Data exchange is not optional, it’s essential,” said Erica Galvez, CEO of Manifest MedEx, one of the state’s nine QHIOs, in a statement. “This law puts in place the accountability needed to ensure every provider and health plan participates fully in the Data Exchange Framework so Californians get safe, well-coordinated, whole-person care.”

Timi Leslie, executive director of Connecting for Better Health, had penned an opinion piece in the Capitol Weekly urging passage of the law. Leslie’s group is a coalition dedicated to enhancing health and social data sharing to improve the health of all Californians.

Leslie wrote that the law proposes inclusion of emergency services to participate in data sharing, “which is vital for optimizing patient health in both personal emergencies and widespread crises, such as California’s seasonal wildfires. SB 660 incorporates necessary community-informed provisions built based on extensive feedback received from DxF participants to secure trusted data connections among partners.”

Leslie also stressed that when providers and other data-sharing participants trust the data they share and use, it unlocks the ability to improve patient outcomes more efficiently. “For instance, if one care provider has already performed bloodwork or an MRI and this information is shareable between providers, care teams can begin treatment more quickly while also helping the patient avoid unnecessary repeat tests.”

In September 2024, Healthcare Innovation reported on a panel discussion about stakeholders' early impressions of the Framework's implementation. 

In that 2024 discussion, David Ford, vice president of health information technology at the California Medical Association, said that if he were to grade the implementation of the Data Exchange Framework, he would give it an incomplete. “There's definitely still some policy work that needs to happen to put the rest of the structure around the Data Exchange Framework,” he explained. “But that being said, we do have 3,000-something entities that have signed. We’re seeing some really great energy and some interest from non-traditional parts of data exchange. The community-based organizations have been some of the earliest ones to raise their hands and say they want to be part of this, and that's been really interesting. It's something I would not have predicted coming into the whole process, But I really would like to see us close those last gaps, and get the rest of the structure in place, so that we can really move forward together.”