C4BH Meeting Provides a Pulse on DSA Engagement, Next Steps

The January 12 meeting of the Connecting for Better Health (C4BH) coalition featured an ambitious agenda and high levels of participant engagement. Meeting attendees voiced apprehension at the updates that accompany the looming January 31 deadline for most providers and health care entities to sign California’s first-ever, statewide Data Sharing Agreement (DSA).

According to the California Health and Human Services’ (CalHHS) Center for Data Insights and Innovation (CDII), 289 accounts have been created within the DSA signing portal. In addition, 34 signatures are in progress and 159 agreements have been executed.

At the January 10 Implementation Advisory Committee Meeting for the Data Exchange Framework (DxF), the application criteria for qualified health information organizations (QHIOs) were published, sparking concern and questions among many. Still, coalition colleagues responded with a renewed commitment to their priorities.

QHIOs are entities designated by the state as health information organizations (HIOs) that DxF signatories can contract with for assistance in meeting the data exchange framework requirements. Emphasis around financial stability and a marked lack of functionality, data quality, and security requirements were all raised as concerns during the January 10 meeting.

According to attendees at C4BH’s January 12 meeting, while the requirements are manageable, they will come at great cost.

John Helvey, executive director of SacValley MedShare, an HIO serving a 21-county region including the North Central Valley and the surrounding mountainous terrain, told C4BH meeting attendees about the necessity to “slow them down in regards to strangling HIOs with more regulations without additional financial support.”

Many HIOs are nonprofit organizations that cannot shoulder the administrative burden required to achieve additional certifications. The inevitable exclusion of such organizations may have far-reaching, unintended, and inequitable impacts, according to Helvey.

Felix Su, director of health policy at Manifest MedEx, interjected that QHIOs need to be situated to serve all potential members of the DSA, including but not limited to health plans, health care providers, and social service providers. The functional requirements and infrastructure necessary to meet these expectations should be reflected in QHIO criteria, he said.

Dan Chavez, executive director of Santa Cruz Health Information Exchange, added that real-time data sharing capabilities are essential to acting on data that include social determinants of health (SDOH), as these situations are prone to shift quickly.

Jim St. Clair, customer innovation advisor at The Interoperability Institute, an Ann Arbor, Mich.-based nonprofit that enables organizations and communities to harness the benefits of interoperability at scale, raised concerns about the lack of cybersecurity requirements. Although insurance can be helpful to cover a business loss, ransomware attacks can be detrimental to patient outcomes, he said.

Following the discussion around the recent DxF updates, Daniel Stein and Dr. Kristine McCoy from the National Interoperability Collaborative (NIC) shared their work that focuses on managing consent in a clear and informed manner, a vital issue that has halted progress for many interoperability programs.

NIC supports pilot programs across the country that utilize consent service utilities to manage a valid and current consent registry that can be found with ease. One of their projects is in the Bronx, N.Y., with a Center for Medicare and Medicaid Innovation (CMMI) project called Integrative Care for Kids, which aims to reduce expenditures and improve care quality for children covered by Medicaid through prevention, early identification, and treatment of behavioral and physical health needs.

McCoy explained that having the consents stored in a consistent “home” allows providers to find and share necessary information, undoubtedly improving patient outcomes and experiences.

The meeting concluded with the consensus that C4BH will compile feedback captured about 42 CFR Part 2 and relay it to the U.S. Department of Health and Human Services’ (HHS) Substance Abuse and Mental Health Services (SAMHSA). The proposed major change that would allow patients with substance abuse disorder to provide a general, one-time consent, was met with support from coalition meeting attendees.


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