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Data Strategy 6 min read Published Updated Credibility 91/100

California Data Exchange Framework

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.

Kodi C.

Editor & Research Lead

Reviewed for accuracy by Kodi C.

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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.

Focus areas

  • 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.

References

Synchronizing DxF data governance with interoperability roadmaps so California providers can evidence compliance and improve patient outcomes.

Data Quality and Governance

Data quality programs should assess whether this development introduces new requirements for data accuracy, completeness, timeliness, or consistency. Data governance frameworks should address the specific implications for data definitions, metadata management, and data lineage documentation.

Data stewardship roles should be clearly defined with accountability for data quality within their domains. Regular data quality assessments should verify that data meets defined quality standards and supports intended use cases.

Data Management Implementation

Data management teams should assess how this development affects data collection, processing, storage, and sharing practices. Policy updates should address any new requirements for data handling, consent management, or purpose limitations. Technical setups should align with documented policies and support audit evidence collection demonstrating compliance with data management requirements.

Ongoing monitoring should verify that data processing activities continue to align with documented purposes and comply with applicable requirements as practices evolve.

Resource Planning and Execution

Resource planning should account for the specific requirements of this development, including staffing needs, technology investments, and external support that may be required. Early identification of resource requirements helps ensure timely execution and avoids delays that may create compliance or operational risks.

Budget allocation should reflect the priority and urgency of setup activities, with appropriate contingencies for unexpected challenges or scope changes. Regular monitoring of resource use helps identify potential issues before they impact timelines or outcomes.

Vendor selection and management processes should address the specific requirements of any external support needed, including evaluation criteria, contract terms, and performance expectations. Effective vendor relationships can significantly accelerate setup timelines and improve outcomes.

Knowledge transfer and documentation should ensure that setup expertise is retained within the organization for ongoing maintenance and future reference. This includes capturing lessons learned, decision rationale, and operational procedures that support sustainable adoption.

Data exchange framework participant requirements

California DxF Phase Two expands participation requirements to additional healthcare entities. Participants must sign Data Sharing Agreements and implement technical connectivity to designated Health Information Exchanges. Assess organizational readiness including interface development, consent management, and data quality procedures.

DxF requires support for specific use cases including treatment, public health reporting, and individual access. Map existing data exchange capabilities to required use cases and identify gaps requiring development.

Privacy and security requirements

California DxF participants must implement privacy protections aligned with state and federal requirements. Sensitive health information categories require improved protections and patient consent. Implement minimum necessary data filtering for exchange transactions.

Security requirements include encryption in transit and at rest, access controls, audit logging, and incident response capabilities. Align security setups with HIPAA Security Rule and DxF-specific technical requirements.

Patient matching and identity management

DxF exchanges require reliable patient matching to prevent misidentification and inappropriate information disclosure. Implement patient matching algorithms meeting DxF accuracy thresholds. Establish procedures for manual review of uncertain matches and resolution of duplicate records.

Identity proofing requirements for patient portal access should meet DxF standards for individual access use cases.

Stakeholder engagement and governance

DxF participation involves governance structures including participant agreements and policy development. Engage with California Health and Human Services Agency on policy questions and setup guidance. Participate in stakeholder forums to influence framework evolution.

Coordinate with trading partners on bilateral testing and operational procedures. Establish relationship contacts for ongoing operational coordination and issue resolution.

Change management and ongoing compliance

DxF requirements will evolve as the framework matures. Establish processes for monitoring requirement changes and assessing organizational impact. Plan for periodic updates to technical interfaces, policies, and procedures.

Resource planning and organizational readiness

DxF participation requires staff resources for setup, testing, training, and ongoing operations. Identify project leads for technical interface development, compliance documentation, and business process integration. Plan for ongoing support needs beyond initial go-live.

Allocate budget for HIE connectivity fees, interface development, and system improvements required to meet DxF technical requirements.

Success measurement and reporting

Define success metrics for DxF participation including exchange volumes, patient matching rates, and user satisfaction. Report outcomes to organizational leadership demonstrating value of health information exchange investment. Use metrics to identify improvement opportunities.

Long-term sustainability planning

Plan for long-term sustainability of DxF exchange capabilities. Build internal expertise, establish vendor relationships, and maintain documentation for staff transitions. Ensure institutional knowledge is retained as the exchange program matures.

Sustainable exchange programs create lasting value for patients and providers through improved care coordination.

Continuous engagement with state agencies ensures alignment with evolving framework requirements.

Early preparation enables successful participation and maximizes exchange benefits.

Phase Two Expansion

California Data Exchange Framework Phase Two extends health information exchange requirements to additional provider categories. Mandatory participation expands data sharing across the healthcare ecosystem. Technical specifications ensure interoperability between participating organizations.

Implementation Requirements

Healthcare organizations must connect to qualified health information organizations and demonstrate data exchange capability. Privacy and security controls must meet HIPAA and California-specific requirements. Compliance verification ensures participating organizations meet technical and operational standards.

Patient Benefits

Expanded data exchange improves care coordination and reduces duplicative testing. Patient access to health records increases transparency and engagement. Data portability enables seamless provider transitions.

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Coverage intelligence

Published
Coverage pillar
Data Strategy
Source credibility
91/100 — high confidence
Topics
California Data Exchange Framework · Health data interoperability · Data governance · FHIR
Sources cited
3 sources (cdii.ca.gov, chhs.ca.gov, healthit.gov)
Reading time
6 min

References

  1. California Data Exchange Framework — cdii.ca.gov
  2. CalOHII Health Information — chhs.ca.gov
  3. TEFCA Framework — healthit.gov
  • California Data Exchange Framework
  • Health data interoperability
  • Data governance
  • FHIR
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