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CAL-DXF PROGRAM

The CAL-DXF Program is a California-focused interoperability support initiative administered by Technology Compliance Partners (TCP). The program supports eligible providers in meeting state data-exchange and DSA participation requirements while maintaining compliance with federal EHR certification standards.

Program Charter

Administered by: Technology Compliance Partners (TCP), a nonprofit Health IT Compliance Board and Vendor Network

Effective Date: October 11, 2025

Last Updated: October 11, 2025

Current Jurisdiction of Administration: State of California

I. Statement of Authority and Regulatory Framework

The CAL-DXF Program operates within the statutory and policy framework established by:

  • Assembly Bill 133 (AB-133);
  • The California Health and Safety Code, as amended by AB-133;
  • The California Health and Human Services Agency's Data Exchange Framework;
  • The California Health and Human Services Agency's Data Sharing Agreement;
  • Applicable federal interoperability standards, including the United States Core Data for Interoperability (USCDI).

AB-133 amended the California Health and Safety Code to require certain Healthcare Entities (HCEs) to participate in statewide health information exchange and authorized the California Health and Human Services Agency (CalHHS) to establish, oversee, and administer the Data Exchange Framework.

The CAL-DXF Program exists to support Healthcare Entities in understanding, navigating, and meeting their obligations under the Data Exchange Framework and the Data Sharing Agreement.

The Program aligns with California Health and Human Services Agency policy and leverages federal interoperability standards, including USCDI Version 2 and evolving standards such as Version 3, to ensure that participating entities meet applicable data formatting, exchange, and interoperability expectations.

II. Purpose and Objectives

Program Purpose

The CAL-DXF Program exists to provide structured administrative, technical, and interoperability governance support to Healthcare Entities required to comply with the California Data Exchange Framework.

Healthcare Entities face:

  • Contractual obligations under the Data Sharing Agreement;
  • Technical requirements related to standardized data formatting;
  • Interoperability requirements for exchange through Health Information Exchanges (HIEs) and other authorized exchange mechanisms;
  • Implementation complexity within existing legacy systems;
  • Evolving regulatory and policy standards.

The CAL-DXF Program provides end-to-end support to assist Healthcare Entities in meeting these obligations in a clear, organized, and sustainable manner.

Program Objectives

The objectives of the CAL-DXF Program are to:

  • Support Healthcare Entities in executing and organizing Data Sharing Agreement participation;
  • Assess current technical and interoperable capabilities against Data Exchange Framework requirements;
  • Assist in implementing systems or modular enhancements necessary to meet USCDI Version 2 data formatting and interoperability standards;
  • Facilitate compliant exchange of required health information through appropriate exchange channels;
  • Provide ongoing guidance and governance support as Data Exchange Framework policies evolve.

The Program functions as a support initiative and is not a regulatory body.

III. Jurisdictional Scope

The CAL-DXF Program operates within the State of California.

The Program serves Healthcare Entities (HCEs), as defined under the California Data Exchange Framework and the Data Sharing Agreement, that are required to participate in statewide data exchange under AB-133 and corresponding California Health and Human Services Agency policy.

The Program is available to eligible Healthcare Entities at any stage of Data Sharing Agreement participation, including:

  • Entities that have not yet executed the Data Sharing Agreement;
  • Entities that have executed the Data Sharing Agreement but require implementation support;
  • Entities seeking ongoing interoperability governance assistance.

IV. Scope of Activities

The CAL-DXF Program provides structured administrative and technical support, including:

1. Data Sharing Agreement Support

  • Assessment of current Data Sharing Agreement status;
  • Portal creation assistance where necessary;
  • Administrative guidance on submission and execution procedures;
  • Explanation of contractual obligations in clear, operational terms.

2. Technical and Interoperability Capability Assessment

  • Evaluation of current health information technology systems;
  • Assessment of whether systems support required USCDI Version 2 data elements and formatting standards;
  • Evaluation of interoperability capacity with Health Information Exchanges and authorized exchange mechanisms.

3. Infrastructure and Implementation Support

  • Identification of technical gaps relative to Data Exchange Framework requirements;
  • Structured implementation planning;
  • Integration of modular systems or enhancements where needed;
  • Implementation of solutions designed to align with USCDI Version 2 and evolving interoperability standards;
  • Alignment of new capabilities within existing workflows to minimize disruption.

4. Data Exchange Validation

  • Confirmation that required data elements are formatted correctly;
  • Verification of exchange capability through appropriate exchange channels;
  • Support for operational readiness under Data Sharing Agreement obligations.

5. Ongoing Governance Support

  • Monitoring of policy updates from the California Health and Human Services Agency;
  • Guidance related to evolving USCDI standards;
  • Support for continued meaningful use of compliant systems;
  • Optional ongoing interoperability governance assistance.

Administrative guidance, assessments, and support provided by the Program are offered at no cost to participating Healthcare Entities.

Implementation of hardware, software, or third-party systems may involve separate vendor agreements, as disclosed in program disclosures.

V. Operational Framework

Program Enrollment

The CAL-DXF Program is initiated upon voluntary enrollment by a Healthcare Entity.

Stage 1 – Administrative Assessment

  • Determine Data Sharing Agreement status (Pending / Executed / Dispute);
  • Provide administrative assistance as needed.

Stage 2 – Technical Evaluation

  • Assess current system capabilities;
  • Identify gaps relative to Data Exchange Framework standards.

Stage 3 – Implementation Planning

  • Develop structured timelines for addressing identified gaps;
  • Coordinate integration or enhancement of required capabilities.

Stage 4 – Operational Validation

  • Confirm ability to generate required USCDI data elements;
  • Confirm interoperability functionality;
  • Designate internal status (Operational / Non-Operational / Ongoing Support).

Stage 5 – Ongoing Support (Optional)

  • Provide updates on policy changes;
  • Offer continued technical and governance support.

Support may conclude when a Healthcare Entity demonstrates operational compliance and elects to self-maintain.

Support remains available upon request.

VI. Documentation and Records

The CAL-DXF Program maintains internal administrative records including:

  • Enrollment documentation;
  • Data Sharing Agreement status designations;
  • Technical capability assessments;
  • Implementation planning documentation;
  • Operational status designations;
  • Ongoing support elections.

Internal designations may include:

  • DSA Pending;
  • DSA Executed;
  • DSA Dispute;
  • Technical Gap Identified;
  • Operational;
  • Non-Operational;
  • Ongoing Support.

Documentation may be retained indefinitely while a Healthcare Entity remains enrolled in the Program.

Transmission of documentation to the California Health and Human Services Agency occurs only where authorized, required, or lawfully requested, consistent with program disclosures.

VII. Limitations of Authority

The CAL-DXF Program:

  • Does not exercise regulatory authority;
  • Does not impose enforcement action;
  • Does not replace oversight by the California Health and Human Services Agency;
  • Does not alter statutory or contractual obligations of Healthcare Entities.

The California Health and Human Services Agency retains delegated oversight authority under AB-133 and the California Health and Safety Code.

VIII. Relationship to Other Programs

The CAL-DXF Program operates as a standalone program within the nonprofit.

Healthcare Entities may independently participate in:

  • The Federal EHR Incentive Grant Recipient Outreach Program;
  • The Bridge Certification Program.

Participation in those programs does not automatically enroll a Healthcare Entity in the CAL-DXF Program.

Enrollment in the CAL-DXF Program requires affirmative participation.

IX. Duration and Sunset

The CAL-DXF Program shall remain active for the duration of the California Data Exchange Framework and corresponding statutory authority under AB-133.

The Program is subject to ongoing board oversight and periodic review.

The administering board reserves the right to amend, refine, expand, or sunset the Program in response to:

  • Statutory amendments;
  • Policy updates from the California Health and Human Services Agency;
  • Modifications to the Data Sharing Agreement;
  • Evolution of federal interoperability standards.

Governance and Oversight

This program operates under the oversight of TCP's governing board. Program structure, scope, and administrative procedures are subject to periodic internal review. Material changes to program scope or eligibility are approved through board governance processes and reflected in the version history below.

Definitions

Assembly Bill 133 (AB 133)
Assembly Bill 133 (AB 133) is a California law enacted in 2021 that amended the California Health and Safety Code and directed the California Health and Human Services Agency (CalHHS) to establish and oversee the California Data Exchange Framework.
AB 133 provides the statutory authority for CalHHS to require certain Healthcare Entities (HCEs) to participate in statewide data exchange, execute the Data Sharing Agreement (DSA), and meet technical and operational requirements related to health information interoperability.
California Health and Human Services Agency (CalHHS)
CalHHS is the state agency delegated oversight authority under AB 133 to administer and enforce the California Data Exchange Framework.
CalHHS develops policies, publishes guidance, issues participation requirements, maintains the Data Sharing Agreement, and oversees compliance expectations for Healthcare Entities subject to the Framework.
Data Exchange Framework (California)
The California Data Exchange Framework is a statewide data sharing program established under AB 133 and administered by CalHHS to enable secure, standardized exchange of health information across the state.
The Framework establishes:
  • Who must participate;
  • What data must be exchanged;
  • How that data must be formatted;
  • How it must be transmitted;
  • When obligations apply.
Participation requires execution of the Data Sharing Agreement and implementation of technical capabilities that support interoperability and standardized data exchange.
Data Sharing Agreement (DSA)
The Data Sharing Agreement (DSA) is a legally binding contract required by CalHHS for applicable Healthcare Entities under the California Data Exchange Framework.
By signing the DSA, a Healthcare Entity agrees to:
  • Exchange health information in accordance with Framework policies;
  • Format data consistent with required interoperability standards;
  • Enable secure transmission of information to other participating entities;
  • Comply with technical, operational, and governance requirements.
Execution of the DSA creates an obligation to meet the Framework's implementation and exchange expectations.
Healthcare Entity (HCE)
A Healthcare Entity (HCE) is an organization or provider type defined by CalHHS as subject to participation requirements under the California Data Exchange Framework.
Depending on classification, this may include:
  • Physician organizations;
  • Medical groups;
  • Management Services Organizations (MSOs);
  • Hospitals;
  • Health plans;
  • Clinics;
  • Other covered provider entities.
Obligation to sign the Data Sharing Agreement depends on entity classification and applicable participation phase.
Interoperability
Interoperability refers to the ability of different health information systems to exchange, interpret, and use patient data in a secure and standardized manner.
Within the California Data Exchange Framework, interoperability means that a Healthcare Entity's system must:
  • Generate standardized data elements;
  • Format data according to required specifications;
  • Transmit that data securely;
  • Receive and incorporate data from other participating entities.
Interoperability typically involves standardized APIs, secure transmission protocols, and structured data formats.
United States Core Data for Interoperability (USCDI)
USCDI (United States Core Data for Interoperability) is a federally developed standard that defines the specific data elements and formats required for interoperable health information exchange.
USCDI establishes:
  • What data must be included (e.g., demographics, problems, medications, labs);
  • How the data must be structured;
  • How systems must represent and exchange that information.
The California Data Exchange Framework aligns with federal interoperability standards, including USCDI Version 2 and evolving versions such as Version 3.
USCDI Version 2 (V2)
USCDI Version 2 (V2) defines a structured set of standardized clinical data elements required for interoperable exchange.
Version 2 expands required categories and supports consistent formatting across participating systems. Many implementation expectations under the California Data Exchange Framework reference alignment with federal interoperability standards consistent with USCDI Version 2.
USCDI Version 3 (V3)
USCDI Version 3 (V3) is a subsequent federal update expanding standardized data elements and interoperability requirements.
While implementation timelines may vary by program or policy phase, Healthcare Entities may need to prepare for evolving standards as interoperability expectations mature.
Health Information Exchange (HIE)
A Health Information Exchange (HIE) is a network or platform that enables Healthcare Entities to securely transmit and receive patient data between organizations.
Under the California Data Exchange Framework, HIEs may serve as a mechanism through which Healthcare Entities satisfy data exchange obligations, provided their systems can generate and transmit required standardized data.
Implementation Requirements
Implementation Requirements refer to the technical and operational steps a Healthcare Entity must complete to meet its obligations under the Data Sharing Agreement.
These may include:
  • Executing the Data Sharing Agreement;
  • Configuring systems to generate required data formats;
  • Enabling secure interoperability;
  • Testing exchange capabilities;
  • Maintaining ongoing compliance as policies evolve.
Implementation obligations arise upon execution of the Data Sharing Agreement and continue thereafter.
CAL-DXF Program
The CAL-DXF Program is an administrative support program operated by Technology Compliance Partners (TCP) to assist Healthcare Entities in meeting their obligations under the California Data Exchange Framework.
The CAL-DXF Program provides:
  • Assistance with Data Sharing Agreement portal setup and execution;
  • Technical capability assessments;
  • Interoperability gap identification;
  • Infrastructure implementation support;
  • Ongoing policy and compliance updates.
The CAL-DXF Program is distinct from the California Data Exchange Framework and is not a state enforcement body. It is a nonprofit administrative support initiative designed to help Healthcare Entities navigate Framework requirements.

Version History

  • Version 1.0 – October 11, 2025 – Initial adoption

For related disclosures, statutory references, and program policies, see the TCP Disclosures Section.