If your California home health or hospice agency has recently received an email asking you to sign a Data Exchange Framework (DxF) Data Sharing Agreement, you may have had the same reaction as many other providers:
Why are we receiving this? Does it actually apply to home health or hospice? And what are we supposed to do after signing it?
Those questions have created understandable confusion because home health and hospice agencies are not specifically listed among the primary provider types most people associate with California's Data Exchange Framework.
*This article was written in consultation with Mariam Treystman.
In our recent webinar, The Home Health Consultant Co-Founder Mariam Treystman broke down what the DxF means for home health and hospice agencies, why an agency's CLIA status matters, and the practical steps affected providers should take.
The key is understanding that signing the agreement is only one part of the process.
What Is California's Data Exchange Framework?
California's Data Exchange Framework establishes common requirements for participating healthcare organizations to securely exchange electronic health information with other authorized participants.
The goal is to:
- make important patient information more accessible to authorized healthcare providers,
- improve coordination between organizations,
- reduce missing information, and support safer patient care.
One important point is what the DxF is not.
It is not simply a central California database containing everyone's patient records.
Instead, the framework establishes what Mariam described as the “rules of the road” for organizations exchanging health information electronically through systems such as their electronic medical record, a Qualified Health Information Organization (QHIO), network, or other intermediary.
In other words, participating organizations need both the rules governing the exchange and a compliant way to actually perform that exchange.
Why Are Home Health and Hospice Agencies Receiving DxF Notices?
This is where much of the confusion begins.
The provider categories discussed in the webinar include organizations such as but not limited to:
- General acute care hospitals
- Certain physician organizations, medical groups, and clinics
- Skilled nursing facilities maintaining electronic health records
- Certain health plans and insurers
- Clinical laboratories
- Acute psychiatric hospitals
- Emergency medical services organizations
Home health and hospice agencies do not appear as a standalone provider category on that list.
However, Mariam explained that an agency holding a California CLIA certificate may fall into the clinical laboratory category for purposes of the requirement.
As Mariam summarized during the webinar:
“If your agency has a CLIA, this is for you.”
For affected agencies, the analysis is not simply, “We are a home health agency, so this does not apply.”
The CLIA component is what requires a closer look.
What Does an Affected Home Health or Hospice Agency Need to Do?
Agencies subject to the requirement should think about DxF compliance in three main steps:
- Sign the Data Sharing Agreement
- Establish a compliant electronic exchange method
- Record that exchange method in the DxF Participant Directory
But each step requires a little more than checking a box.
The agency also needs to understand how requests will actually be received, reviewed, fulfilled, and documented.
Step 1: Sign the Data Sharing Agreement
The first step is the most straightforward.
The agreement establishes that the organization will follow California's rules for secure electronic health information exchange.
Signing it does not mean that every request for patient information must automatically be fulfilled.
The agency remains responsible for determining whether a request is valid and whether disclosure is legally permitted.
That includes continuing to follow applicable HIPAA requirements, California privacy requirements, and the agency's normal procedures for verifying the identity, authority, and purpose of someone requesting patient information.
As Mariam cautioned, simply receiving a request through an electronic exchange does not automatically make it appropriate to release the information.
Step 2: Determine Whether Your EMR Can Handle DxF Exchange
The next question should be directed to your EMR vendor:
Can our current system actually support the required electronic exchange?
Mariam recommends contacting the EMR in writing and obtaining the answers in writing so the agency has documentation of what the vendor represented.
Do not stop at asking, “Are you DxF compatible?”
That answer may not tell you whether your agency is actually connected and operational.
Instead, ask more specific questions, including:
- Are we currently connected to a DxF-compatible exchange, or is the software only technically capable of connecting?
- If we are connected, which network or QHIO is being used?
- Does the connection include the CLIA-waived laboratory information maintained by our agency?
- Are incoming requests answered automatically or placed into a staff work queue?
- Where will failed transmissions, patient-matching errors, or other problems appear?
- Who at the agency needs to monitor incoming requests?
- Can the system produce an audit log showing requests and disclosures?
These operational questions matter.
As Mariam explained, it is not enough for a vendor to simply tell you, “Yes, we're connected.”
Your agency needs to know what that connection actually means in day-to-day operations.
What If Your EMR Cannot Provide the Connection?
If the agency's EMR is not connected or cannot adequately support the required exchange, the next option is contracting with a California-designated QHIO.
Before selecting a vendor, the agency should confirm that the organization can actually work with home health, hospice, and small CLIA-waived laboratories.
Useful questions include:
- Do you onboard home health and hospice agencies with CLIA-waived testing?
- Can you integrate with our current EMR?
- Can you exchange the limited laboratory and clinical information our agency maintains?
- What are the onboarding requirements?
- What agreements are required?
- What will implementation cost?
- How will ongoing monitoring work?
Agencies should also ask how long implementation will take.
Onboarding may take less than 90 days in some situations and 90–180 days in others, depending on the vendor and implementation.
That means agencies should not assume they can wait until the last minute, sign a vendor agreement, and instantly have a functioning connection.
What Information Would a Home Health or Hospice Agency Exchange?
For a home health or hospice agency participating because of its CLIA status, the expected information is relatively limited.
The focus would generally be on the CLIA-waived laboratory information the agency actually maintains, rather than sending an entire home health or hospice medical record every time someone requests information.
For example, depending on the testing performed, another treating provider might be seeking a laboratory result available through the agency.
Potential requesters include but are not limited to:
- Hospitals and emergency departments
- Physicians and medical groups
- Skilled nursing facilities
- Clinical laboratories
- Health plans and Medi-Cal managed care plans
- Other treating providers
- Patients or authorized representatives
- Authorized public health or government agencies
The important point is that the agency is not simply opening its medical record to anyone participating in the system.
An Electronic Request Still Has to Be Valid
The electronic nature of the exchange does not eliminate the agency's responsibility to protect patient information.
A requesting organization must have a legally permitted reason to request the information, including but not limited to:
- treatment,
- payment,
- healthcare operations,
- public health,
- or individual access
The QHIO or other intermediary helps facilitate the exchange. It does not independently decide that someone should have access to a patient's information.
As Mariam emphasized:
“Just because it comes through the portal doesn't mean that it's going to be valid.”
Agencies therefore still need processes for verifying requests and determining whether information may legally be disclosed.
They also need to continue complying with HIPAA, applicable California privacy laws, security requirements, breach-reporting obligations, and rules against improper access, misuse, or sale of patient information.
Step 3: Update the DxF Participant Directory
Once the agency has determined how it will participate, whether through its existing EMR or another exchange vendor, it still has another step to complete.
The agency must record its selected exchange method in the DxF Participant Directory and keep that information current.
Mariam summarizes the process this way:
Sign the agreement → Confirm or establish the electronic connection → Record the connection in the Participant Directory
That simple sequence is a useful way for agency leadership to track whether the requirement has actually been completed.
Important Note: Signing the agreement alone does not establish the exchange. And contracting with a vendor without documenting the connection in the required directory does not finish the process.
Do Not Ignore the Requirement Because You Are Unsure How Often It Will Be Used
One of the more practical points is that home health and hospice agencies may ultimately receive relatively few requests through this system.
For an agency performing only limited CLIA-waived testing, it is reasonable to wonder how frequently another provider will actually request that information.
But uncertainty about how often the system will be used is different from determining whether the agency is expected to comply.
We want to caution agencies against ignoring newer or unclear requirements simply because enforcement has not yet been visible.
The safer approach is to establish the process now and maintain documentation demonstrating what was done.
What Home Health and Hospice Agencies Should Do Now
If your agency received a California DxF notice, begin by determining whether your agency's California CLIA status is what is bringing you within the requirement discussed in the webinar.
If it is, do not stop after signing the agreement.
Contact your EMR in writing and determine whether you already have a functioning DxF-compatible exchange connection. If not, evaluate an appropriate QHIO or other exchange option.
Then make sure your agency understands:
Where requests will appear, who will monitor them, how requests will be validated, what information can be exchanged, how disclosures will be documented, and who is responsible for keeping your DxF information current.
The technology may be new, but the underlying compliance principle is familiar: know where patient information is going, make sure disclosure is permitted, and document the process.
Need Help With California DxF Compliance?
If your home health or hospice agency has a California CLIA certificate and you are unsure whether your DxF setup is complete, The Home Health Consultant can help you work through the requirement.
Our team can help you understand what applies to your agency, identify the questions you need to ask your EMR or QHIO, and make sure you have addressed the key steps discussed in this article.
Contact The Home Health Consultant today to review your agency’s DxF compliance and determine what you still need to complete.
If your agency needs ongoing support beyond DxF, our Administrative Compliance Program provides year-round guidance on home health and hospice compliance, survey readiness, and changing state and federal requirements.
*Disclaimer: The content provided in this article is not intended to be, nor should it be construed as, legal, financial, or professional advice. No consultant-client relationship is established by engaging with this content. You should seek the advice of a qualified attorney, financial advisor, or other professional regarding any legal or business matters. The consultant assumes no liability for any actions taken based on the information provided.
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