1. Overview

Purpose. This policy sets out the requirements that every organization connecting through Particle Health ("Connection") must meet to participate in bi-directional health information exchange. These requirements exist because the networks Particle connects to, principally Carequality, CommonWell, eHealth Exchange, and TEFCA, operate on a principle of reciprocity: if you query the network for patient records under a treatment purpose of use, you must also make your patient records available to the network when others query for them.

Why this matters. Under the Carequality Framework, any entity that initiates queries for Treatment purposes must also serve as a Query Responder for Treatment purposes. Under the TEFCA Common Agreement, Responding Nodes must respond to queries for all exchange purposes identified as "required" in applicable Standard Operating Procedures, and the response must include all Required Information. Particle Health, as an Implementer, is responsible for ensuring that every Connection meets these obligations. Failure to comply puts Particle's network access at risk, which in turn affects all Connections.

Scope. This policy applies to all organizations that query for patient records through Particle Health's platform under a treatment purpose of use, regardless of which network integration (Carequality, CommonWell, or eHealth Exchange) they use.

2. The Core Obligation: If You Query, You Must Respond

Every Connection must both send and receive patient data through the network. Specifically:

Query Responder duty. If your organization queries for patient records through Particle, you must also make your full and complete patient records available when other network participants query for them.
Accurate representation. The data you make available must be an accurate representation of the information contained in your system at the time you generated it.
Non-discrimination. You may not limit exchange with any other participant in a discriminatory manner for required exchange purposes.
Required exchange purposes. As of the date of this policy, all Responding Nodes must respond to queries for TEFCA Required Treatment (T-TRTMNT) and Individual Access Services (T-IAS). Under Carequality, responding to Treatment queries is mandatory, and responding to Patient Request and Care Coordination queries is strongly encouraged. If you choose to respond for any optional permitted purpose, you must respond to queries for that purpose from all Query Initiators on a non-discriminatory basis.
Limited exceptions. A Connection may operate as a query initiator only (without responding) if it: (a) is a provider organization with no electronic clinical information; (b) is an EMR provider with alternative data-sharing methods; (c) has a valid Initiator Only Attestation under the Carequality Delegation of Authority framework; or (d) is prohibited from responding by applicable law.
Attributed populations. Your organization may query for records on patients in your attributed population (e.g., patients attributed under a value-based care arrangement) even if you do not currently hold medical records for those patients. The reciprocity obligation requires you to make available the data you have in your systems; it does not require you to possess existing records as a precondition to querying. Your data submission obligations for these patients begin if and when your organization collects or generates clinical data about them, as described in Section 4.

3. Pre-Launch Requirements

Before a Connection may begin production query volume, the following must be satisfied:

a. Test data submission. During implementation, you must demonstrate your ability to submit records through Particle's Bi-Directionality API as part of integration testing. If your organization holds existing records for patients included in your test queries, those records must be posted within one (1) month of the initial test queries. If you are querying on an attributed population for which you do not currently hold medical records (for example, to identify care gaps), you are not required to submit historical data for those patients as a precondition to testing. You must still demonstrate a functional data submission workflow using patients for whom you do have records, or by submitting any new data generated during the testing period.

b. Demonstrated push capability. You must demonstrate the ability to push data to Particle's Bi-Directionality API on a recurring monthly basis.

c. Reciprocity verification. Within two (2) weeks of activation, Particle must confirm that your organization is uploading patient documents to be available for response to inbound queries in compliance with Carequality's reciprocity requirements. Production query access will not be granted until this verification is complete.

4. Ongoing Data Submission Requirements

Once live, every Connection must maintain its data contributions on an ongoing basis:

a. Historical records. For any patient you create through the Particle Patients API for whom your organization holds existing medical records, you must submit that patient's historical records within one (1) month of creating the patient. For patients in your attributed population for whom you do not hold existing records (e.g., members you are querying to identify care gaps in order to provide medical treatment), no historical data submission is required at the time of patient creation. Your submission obligation for these patients begins when your organization first collects or generates clinical data about them, at which point Section 4(b) timelines apply.

b. New data. Any net new data you collect or generate about a patient must be posted within one (1) month of when the data was collected or generated. This includes, but is not limited to:

Data from new patient encounters
Updates to treatment recommendations or care plans Identified care gaps or risk assessments
Lab results, imaging, or clinical notes produced by your organization

c. Net-new data only. The data you submit to the network must be data that originated in your system. Do not re-submit data you previously retrieved from the network, as this creates duplicate records and degrades data quality across the ecosystem.

d. Continuous completeness. Your data submissions must fully and completely represent the data and resources available in your systems for each patient, updated on an ongoing basis. This is not a one-time obligation; it continues for as long as you are querying the network. For patients for whom you do not hold any records, this obligation is satisfied; you are required to share data you have, not to produce data you do not have.

5. When Queries Do Not Generate New Data

Not every query will result in new data being created in your system. The reciprocity obligation requires you to share data you have, not to create data you do not have. Common scenarios where a query occurs but no net-new data is generated include:

Attributed population queries with no existing records. Your organization queries records for patients in your attributed population to assess their health status or identify care gaps. You may not hold any existing medical records for some or all of these patients. Because your organization has no data of its own for these patients, there is nothing to submit to the network. Your submission obligation begins only if and when you collect or generate new clinical data about a patient (for example, through a subsequent encounter or clinical intervention).
Care gap identified but no treatment provided. After retrieving and reviewing a patient's records, your organization determines no intervention is needed, or the patient declines the recommended treatment. No clinical encounter occurs and no new clinical data is created in your system.
Record review without a patient encounter. A care coordinator or case manager reviews a patient's external records for informational purposes (e.g., confirming medication history, preparing for a future visit) without conducting a clinical encounter or generating new documentation.
Monitoring with no new events detected. You have subscribed to ongoing monitoring for a patient through Particle, but no new encounters or health events have occurred since the last data submission.

In each of these scenarios, your organization has no new data to contribute and is not expected to submit data. Your reciprocity obligation is satisfied by ensuring that when you do have data in your system for a queried patient, that data is made available to the network within the timelines described in Section 4.

6. Dataset Requirements

a. Format.

Preferred: C-CDA 2.1 (XML format). This is the primary expected format for document exchange across Carequality and TEFCA. Responding organizations should follow the Concise Consolidated CDA content guide.
Acceptable alternative: PDF or other plain document formats (e.g., JPEG) with appropriate format codes and MIME types, for organizations with limited technical capacity to produce structured C-CDA documents.
eHealth Exchange participants: If your organization uses Particle's eHealth Exchange integration in addition to Carequality and CommonWell, C-CDA documents in XML format are preferred. eHealth Exchange participants must commit to fulfilling all applicable eHX requirements within six (6) months of activation. Contact your Particle Health representative for details.

b. Content standard.

Data should conform to USCDI v3 data classes, data elements, and vocabulary requirements, which is the version required under both ONC certification (45 CFR § 170.213) and the TEFCA QTF v2.0 as of January 1, 2026. For the full list of applicable data classes and data elements, refer to the current version of the USCDI standard published by ASTP/ONC at healthit.gov/uscdi.

c. Flexibility. If your organization cannot produce the full dataset above, there is flexibility to limit what is shared based on your technical capabilities and the data available in your systems. Contact your Particle Health representative to discuss.

7. Accountability and Enforcement

Particle Health is required to report bi-directionality metrics to Carequality and is responsible for ensuring that all Connections participate according to network agreements. Carequality reserves the right to take enforcement action, including suspension or termination of exchange access, against organizations that violate these requirements. If Particle is found non-compliant due to a Connection's failure to meet its obligations, the Carequality Steering Committee may extend corrective action plans, prohibit new directory entries, or immediately suspend Particle from exchange.

Particle will suspend a Connection's query access if any of the following occur:

Failure to submit data. The Connection is querying the network but not submitting patient records for patients for whom it holds data, in conjunction with those queries.
Incomplete patient data. Historical records are not provided for queried patients for whom the Connection holds records, or new data available in the Connection's systems is not being made available in a timely fashion.
Unusable data. The data being shared would not be helpful to a provider at the point of care.

These enforcement measures protect Particle and all of its Connections from network-wide suspension.

8. Questions

Contact your Solutions Architect or Customer Success Manager with any questions about this policy or your bi-directionality obligations.