QHIOs and DxF in California: Everything you need to know
California interoperability compliance has officially entered a new chapter.
The California Data Exchange Framework, also known as DxF, is something healthcare organizations must actively address. This began in 2021 when Governor Newsom signed Assembly Bill 133. More recently, with SB 660 signed into law in October 2025, California is formally requiring the state to identify and publicly list noncompliant organizations and enabling referrals to licensing agencies.
Acting now helps avoid scrutiny later.
If you operate in California, these healthcare laws apply to you. And you’re not alone. More than 4,400 healthcare organizations across California are already participating, making DxF compliance the emerging standard for care coordination statewide.
The goal is simple: Remove data silos, improve data exchange, and support whole-person care.
In this blog, we break down a complex mix of new enforcements and terminology, so California organizations know exactly what’s required, why it matters now, and what actions to take next.
The big picture behind the California DxF
California’s data exchange framework was created to support secure, timely sharing of health information across the care continuum. It’s designed to ensure that providers can access the information they need when they need it.
This framework is rooted in two major pieces of healthcare regulation: Assembly Bill 133 and Senate Bill 660.
Together, they define how data exchange must work in California and who is responsible for making it happen. At its core, DxF focuses on three types of data exchange:
- Clinical data exchange
- ADT alerts
- Social services data exchange in future phases
Right now, the emphasis is on clinical data and ADT alerts.
AB 133 explained in plain language
AB 133 was signed into law in 2021, with the purpose of removing data silos and enabling real-time data sharing to support whole-person care. It established California’s commitment to interoperability in healthcare and set expectations for who must participate, which includes skilled nursing facilities.
AB 133 also led to the creation of Qualified Health Information Organizations, or QHIOs.
What is a QHIO and why does it matter?
A QHIO is a certified organization authorized by the state of California to facilitate health data exchange under the DxF. California certified nine QHIOs.
QHIOs serve as trusted intermediaries to help ensure data exchange happens securely, at scale, and in compliance with healthcare laws. Not all data must flow directly through a QHIO, but QHIOs play a central role in enabling and managing interoperability across networks.
Choosing a QHIO is not optional. Every covered organization must designate one as part of DxF participation.
How clinical data exchange works today
Clinical data exchange under the DxF is already live. This exchange happens through national networks including Carequality, eHealth Exchange, and TEFCA.
Through these networks, providers can securely request and retrieve patient information such as:
- Hospital records
- Lab results
- Continuity of care documents
- Provider documentation
This supports EHR interoperability across care settings. For example, with MatrixCare, users can request patient documents, review them, and decide what to bring into the chart with no separate system to manage and no custom build required.
At the same time, patient CCDs are automatically shared back to the national network when key updates occur. That includes changes to medications, diagnoses, allergies, and census events.
This is EHR and interoperability working together in real time.
ADT alerts and what’s coming next
ADT (admit, discharge, and transfer) alerts are another key requirement under the data exchange framework. These alerts notify other organizations when specific patient events occur or when patient demographics change.
- ADT alerts are HL7 messages triggered automatically by systems when an action happens. They help keep care teams informed and coordinated.
- California requires ADT alerts as part of DxF compliance.
- Implementation is underway and continues through 2026.
SB 660 and why enforcement is changing
In October 2025, California passed SB 660, a law that builds on AB 133 and introduces meaningful changes.
SB 660 does three important things:
- Shifts oversight and enforcement of the data exchange framework to a new agency: The Department of Health Care Access and Information, also known as HCAI
- Expands compliance requirements to include emergency medical services organizations
- Introduces stronger enforcement mechanisms
HCAI will begin actively tracking participation and auditing compliance. Organizations that have not taken steps toward compliance will stand out quickly, which is why acting now matters.
Signing the required agreements and registering with the state demonstrates good-faith participation and positions organizations ahead of enforcement activity.
The actions California healthcare organization must take
There are clear steps every California organization must complete to meet DxF requirements.
Step 1: Sign the data sharing agreement
Organizations must sign the California Data Sharing Agreement through the state portal. This registration generates a unique DxF number that identifies your organization as participating. It’s an essential step that signals to the state that you are engaged and moving toward compliance.
Step 2: Select a QHIO
Every organization must designate a QHIO.
Step 3: Share your DxF number
Once registered, provide your DxF number with a trusted vendor. This allows validation, setup coordination, and training to begin.
Step 4: Activate clinical data exchange
With setup complete, clinical data exchange through national networks can be turned on. This puts your organization on the path to compliance while delivering immediate operational value.
How MatrixCare and Health Gorilla support DxF compliance
With Health Gorilla (one of the nine QHIOs certified by California), MatrixCare offers secure, scalable data exchange that meets both state and federal requirements. Health Gorilla serves as MatrixCare’s interoperability and QHIO gateway. Together, we help facilities experience:
- Secure nationwide clinical data exchange
- Built-in compliance with California healthcare regulation
- Seamless access to national networks
- A future-ready interoperability foundation
All of this is embedded into existing MatrixCare workflows, without adding integrations, systems, or complexities.
What compliance looks like inside MatrixCare
With MatrixCare and Health Gorilla, compliance is operationalized, helping your team:
- Secure access to hospital, lab, and provider records
- Share continuity of care documents automatically
- Reduce manual chart chasing
- Accelerate admissions and transitions of care
- Leverage built-in support for EHR interoperability
MatrixCare delivers California-ready interoperability that is embedded in a way that is clear, achievable, and supports the work care teams do every day.
Ready to feel confident about QHIOs and DxF in California?
Michele Spadola
Michele is a Senior Product Manager in Interoperability at MatrixCare, specializing in Senior Living and Long-Term Care (SLTC). Since joining MatrixCare in 2016, she has leveraged her 17 years of experience in the healthcare industry, which began with a primary care physicians group before focusing on SLTC. With over 30 years of professional experience across various industries, Michele has developed a strong expertise in managing certification and integration projects, leading to her current role in product management.
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