AB 133: Where Are We Now?

Health and social services organizations prepare to implement the Data Exchange Framework.

Assembly Bill 133 (AB 133), the Health Omnibus Trailer Bill, was signed into law by Governor Gavin Newsom in July 2021. AB 133 supports data sharing among health care and social services organizations in California and requires the California Health and Human Services Agency (CalHHS) to develop a Data Exchange Framework (DxF). In the two years since its passage, there has been significant progress towards the implementation of the nation’s first statewide bidirectional data exchange framework. 

Here C4BH answers questions that provide an update on AB 133.

Question: What did AB 133 do, and why is it important?

Answer: The DxF is an agreement among health and social services organizations to securely and appropriately share health information. The DxF governs how entities must share information about their patients with other framework participants. By exchanging information safely and in a timely fashion, organizations are better able to support the goals of California Advancing and Innovating Medi-Cal (CalAIM). A long-term commitment to transform and strengthen Medi-Cal, CalAIM offers Californians a more equitable, coordinated, and person-centered approach to maximizing their health and life trajectory.

Question: What has been accomplished so far?

Answer: Since AB 133 was signed into law, there have been numerous actions taken towards implementation. In August 2021, the Stakeholder Advisory Group was established. ​​In July 2022, the Data Sharing Agreement (DSA) was finalized with an initial set of policies and procedures (P&Ps), and more P&Ps are in development. The Implementation Advisory Committee (IAC) and the Data Sharing Agreement and Policies & Procedures Subcommittee continue to meet to engage stakeholders in implementation planning and P&P development.

In 2023, the Center for Data Insights and Innovation (CDII) developed criteria and a process for the Qualified Health Information Organization (QHIO) program. The application opened in 2023, and the first set of QHIOs was expected to be announced soon.

CDII also launched multiple grant initiatives to fund the implementation of the DxF. The DxF Educational Initiative Grant Program currently funds eight nonprofit organizations to provide education and training on the DxF across the state. The DSA Signatory Grant Program provides funding to signatories to help subsidize their implementation efforts. The Signatory Grants are expected to be awarded in three rounds during summer months of 2023. 

Most health care organizations will begin exchanging data by January 2024. Some organizations, including physician practices with fewer than 25 physicians, will have until January 2026 to begin exchanging data.

Question: How are organizations preparing for AB 133 to go into effect?

Answer: As of March 2023, over 1,400 organizations have signed the CalHHS DxF DSA, and more are required to sign immediately. Organizations should next consider the business and legal implications of signing the DSA to prepare for it to go into effect in 2024. 

Question: What are the key P&Ps in the DSA?

Answer: The P&Ps developed so far address the following:

  • Requirement to exchange health and social services information
  • Data elements to be exchanged 
  • Methods to exchange data 
  • Permitted, required, and prohibited uses
  • Breach notification
  • Individual access services

The P&Ps, which are currently in development, are:

  • State-specific information blocking prohibitions 
  • Technical requirements for exchange 
  • Real-time exchange and early exchange
  • Additional privacy standards and security safeguards

To learn more, visit our data exchange information hub.


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