C4BH Letter to California Assembly Committee on Health Regarding AB 1331 

Health and social data sharing across the state of California is vital to the success of California Advancing and Innovating Medi-Cal (CalAIM) and other innovative initiatives to improve Californians’ lives. Assembly Bill 1331 (AB 1331) is a key element of improving our infrastructure. 

AB 1331 will grant CDII the authority to establish a DxF governing board and update the Data Sharing Agreement (DSA) and its policies and procedures

To support this work, changes are needed to state law to grant the California Health and Human Services Agency (CalHHS) Center for Data Insights and Innovation (CDII) the authority needed to set up a Data Exchange Framework (DxF) governing board and continue to refine the Data Sharing Agreement (DSA) and its policies and procedures.

Connecting for Better Health (C4BH) submitted an April 12 letter to Assembly Member Jim Wood (D-Healdsburg) and the California Assembly Committee on Health to recommend some changes to the bill and request an affirmative vote. 

C4BH’s seven recommendations to amend AB 1331:

1. Include references to both health and social services information to support a whole-person approach to data sharing.
2. Provide clear definitions and references for entities required to sign and share data under the DSA.
3. Set new dates for the requirement to sign the DSA.
4. Grant clear authority to the CDII to add additional categories of entities to the required list of signatories and to enforce regulations and conduct investigations related to the DSA.
5. Reduce the number of representatives on the proposed Data Exchange Board and clarify the board’s intent in advancing California’s health care access, equity, affordability, public health, and quality programs and goals.
6. Establish a cross-agency task force composed of representatives from state agencies to coordinate funding and policy strategies related to data sharing. 
7. Create a Qualified Health Information Advisory Group that will provide recommendations on the technical standards, policies, and procedures related to qualified health information organizations (QHIOs) serving as data-sharing intermediaries.
8. Include references to both health and social services information to support a whole-person approach to data sharing.
9. Provide clear definitions and references for entities required to sign and share data under the DSA.
10. Set new dates for the requirement to sign the DSA.
11. Grant clear authority to the CDII to add additional categories of entities to the required list of signatories and to enforce regulations and conduct investigations related to the DSA.
12. Reduce the number of representatives on the proposed Data Exchange Board and clarify the board’s intent in advancing California’s health care access, equity, affordability, public health, and quality programs and goals.
13. Establish a cross-agency task force composed of representatives from state agencies to coordinate funding and policy strategies related to data sharing.
14. Create a Qualified Health Information Advisory Group that will provide recommendations on the technical standards, policies, and procedures related to qualified health information organizations (QHIOs) serving as data-sharing intermediaries.

C4BH proposed these changes to AB 1331 to strengthen the bill by encouraging entities to sign the DSA, promoting transparent engagement with state agencies and stakeholders, and allowing for necessary changes to be made to the DSA and its policies and procedures.