Data Strategy Briefing — October 15, 2025
California’s Data Exchange Framework enters its second phase on January 31, 2026, requiring healthcare entities to share expanded data elements and document governance that aligns with the statewide data sharing agreement.
Executive briefing: California Health & Human Services (CalHHS) set January 31, 2026 as the deadline for Data Exchange Framework (DxF) participants to exchange the full set of clinical data elements defined in Attachment C of the state Data Sharing Agreement. By mid-October 2025, integrated delivery networks, hospitals, and payers need validated mappings for laboratory results, imaging, and social determinants data while demonstrating executive oversight of security, consent, and patient access obligations.
Key data governance checkpoints
- Data inventory expansion. Extend DxF data inventories beyond the initial 2024 core data elements to include encounter, laboratory, imaging, and care plan datasets required for Phase 2 exchange.
- Trust framework compliance. Align policies with Attachment D security requirements covering access controls, breach response, and audit logging.
- Consent and authorization. Refresh patient communication journeys to reflect statewide sharing expectations while respecting stricter consent rules for sensitive services under California law.
Operational priorities
- Interface readiness. Map DxF payloads to HL7 FHIR Release 4 and validate interoperability with Qualified Health Information Organizations (QHIOs).
- Data quality monitoring. Implement completeness and timeliness scorecards that surface gaps in mandated fields such as laboratory codes, discharge dispositions, and care team assignments.
- Escalation governance. Define accountability between privacy, security, and clinical informatics teams for responding to DxF compliance issues within mandated timeframes.
Enablement moves
- Run tabletop exercises with QHIO partners to rehearse breach notifications, patient opt-outs, and data correction workflows.
- Leverage DxF implementation grants and technical assistance programs to accelerate interoperability upgrades for safety-net providers.
Sources
- CalHHS Data Sharing Agreement Attachments
- CalHHS DxF implementation timeline
- McDermott Will & Emery: California DxF key deadlines
Zeph Tech synchronises DxF data governance with interoperability roadmaps so California providers can evidence compliance and enhance patient outcomes.