Rym Cothran and Jacob Parkinson outlined forthcoming policy-and-procedure (PNP) amendments intended to align the Data Exchange Framework with statutory changes and stakeholder feedback.

Rym Cothran said stakeholders supported requiring skilled nursing facilities (SNFs) that have the technical capability to send admissions and discharges to participate in event notifications, but that many SNFs lack electronic health records and that a January 1, 2027 date for broad SNF participation may be too soon for some facilities. "There was a strong opinion that 01/01/2027 may be too soon for skilled nursing facilities to participate," Cothran said.

On notification format, Cothran said HCAI does not intend to require human-readable notifications because of the burden on participants; instead, the PNP will retain machine-readable standards, citing HL7 message formats as the machine-readable standard for event notifications. She said HCAI will formalize "rosters" as a mechanism to request notifications and will establish content requirements for event-notification messages.

Cothran also described a PNP clarification that would prohibit using sex or gender attributes for person-matching decisions to reduce the risk of unintentional disclosure of gender-affirming care. She emphasized that the restriction applies to matching only: "Just for matching... it is not a prohibition for exchanging that information," Cothran said, noting that existing standards (including USCDI fields) still allow exchange of gender-related attributes when required by the technical standard.

HCAI said it will remove prescriptive specifications for nationwide network technical standards from the PNP (recognizing those organizations already set their own technical requirements) but will clarify that nationwide networks and frameworks may be used to meet DXF obligations. The department expects to publish a full PNP amendment in early 2026 and to make new requirements effective no sooner than 180 days after publication.

The meeting did not include a formal vote; staff solicited stakeholder feedback and said they will open a short public-comment window before publishing the formal amendment.