California’s Data Sharing Agreement: 6 Things to Know

California’s Data Sharing Agreement: What Do I Need to Know?

In July 2021, California Governor Gavin Newsom signed Assembly Bill 133 (AB 133), the Health Omnibus Trailer Bill. AB 133 mandated data sharing for health care providers in California and required the California Health and Human Services Agency (CalHHS) to develop a Data Exchange Framework

The Data Exchange Framework is a single data sharing agreement that certain organizations and providers in California are required to sign and comply with. 

 6 Things to Know About The CA Data Sharing Agreement

  1. The data sharing agreement doesn’t create a state-wide, centralized health information exchange within California; rather, it requires certain organizations or providers to share information with each other in real time.  
  2. The mandated health information exchange includes electronic data such as immunizations, allergies, medications, and clinical notes, among others. 
  3. State and federal privacy laws, such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA), still apply when exchanging health information with other entities that have signed the data sharing agreement. 
  4. Policies and procedures outlining technical requirements, real-time data exchange, information blocking, and early exchange, are currently being finalized. 
  5. The state created a class of Qualified Health Information Organizations (QHIOs) to help organizations facilitate exchange and meet these requirements. 
  6. Providers can reach out to multiple state-appointed organizations for educational assistance regarding California’s data exchange framework. 

What Organizations Need to Start Sharing Data As a Result of California’s Data Sharing Agreement? 

 Data Sharing Agreement Requirements by January 31, 2024: 

  • General acute care hospitals 
  • Physician organizations and medical groups
  • Skilled nursing facilities (SNFs)
  • Health care service plans, or health maintenance organizations (HMOs)
  • Disability insurers   
  • Medi-Cal managed care plans, or managed care organizations (MCOs)   
  • Clinical laboratories
  • Acute psychiatric hospitals


 Data Sharing Agreement Requirements by January 31, 2026    

  • Physician practices of fewer than 25 physicians   
  • Rehabilitation hospitals
  • Long-term acute care hospitals 
  • Acute psychiatric hospitals   
  • Critical access hospitals (CAHs) with fewer than 100 acute care beds 
  • Rural general acute care hospitals with fewer than 100 acute care beds
  • State-run acute psychiatric hospitals
  • Any nonprofit clinic with fewer than 10 health care providers 

Over 1,400 organizations across the state have now signed the state’s data sharing agreement, signaling California’s commitment to working together to improve residents’ well-being through data exchange. 

To learn more, visit our data exchange information hub

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