As California works on creating its own Data Exchange Framework (DxF), stakeholder feedback has identified several challenges around the role and long-term sustainability of Qualified Health Information Organizations (QHIOs).

Speaking during an April 16 DxF Stakeholder Advisory Committee Meeting, Jacob Parkinson, Data Exchange Framework program director, said that during listening tour sessions the stakeholders highlighted challenges with technical integration across disparate health information systems and the need for more seamless data connectivity. “They described mixed experiences with selecting, implementing, and effectively exchanging data using a Qualified Health Information Organization,” he said. 

California is expecting QHIOs to play a key role in the success of the DxF, filling gaps in California’s data exchange infrastructure by facilitating connections between participants through the secure exchange of health and social services information.

The nine organizations designated as QHIOs are:
• Applied Research Works Inc.
• Health Gorilla Inc.
• Long Health Inc.
• Los Angeles Network for Enhanced Services (LANES)
• Manifest MedEx
• Orange County Partners in Health-Health Information Exchange (OCPH-HIE)
• SacValley MedShare
• San Diego Health Connect
• Serving Communities Health Information Organization (SCHIO)

An Implementation Priorities Background background white paper for the stakeholder meeting noted that the state Department of Health Care Access and Information (HCAI) and DxF participants have identified gaps in the QHIO program and some QHIOs’ capacities to serve DxF participants, including:
• Attestation-Based Qualification. Initial reliance on attestations rather
than demonstrated capabilities has led to variability in service levels
and limited accountability for meaningful progress since the QHIO
program launched in October 2023.
• Voluntary Utilization. Participants’ ability to use any network, health
information organization, or technology under state law means participants are not required to use QHIOs, limiting the impact of the QHIO program on achieving DxF goals.
• Limited Collaboration. QHIOs have demonstrated limited collaboration
with one another, compounding the challenges in building a cohesive
statewide exchange network.
• Inconsistent Service Offerings. QHIOs do not all offer the same services or serve the same participants, and many do not support the broad set of health and social services information exchange available under the DxF, resulting in uneven coverage across use cases, geographies, and participant types.
• Sustainability Concerns. The demand for all QHIOs to deliver statewide
query, information delivery, and event notification services—despite the
variation in their size, service areas, and participant types—has led to
QHIO sustainability challenges for some.

The paper notes that the DxF experience with statewide exchange of event notifications helps illustrates some of the QHIO program’s challenges. So far, QHIOs are not successfully exchanging events or requests for notifications with each other, and the voluntary use of a QHIO required by law means that participants who choose not to use a QHIO may need to create many independent connections to receive event notifications from across the state.

While the current structure and requirements of the QHIO program have not achieved statewide event notification, nationwide networks (e.g., Trusted Exchange Framework and Common Agreement (TEFCA)) do not yet offer an alternative.

A second stakeholder advisory committee meeting is scheduled for June 18.