Completing DAuth Notices

Roles

Particle has customers that are both Delegates and Principals. We have different actions we take as an Implementer of a Principal vs Implementer of a Delegate. Please see below sections outlined based on your designation -- we have different obligations and tasks in each section and are ready to collaborate as needed with other Implementers on the network.

Principal
System of a Principal
Delegate
- initiating only Delegate
- full responding Delegate
- downstream Delegate
Implementer
- Implementer of the Principal
- Implementer of the Delegate

Contact us

Contact: [email protected] Please send all related questions, issues, or submissions to this dedicated DAuth email address. You can also request to book time with Particle's Technical Compliance Lead for any support or guidance on this new policy.

Note: On completion of any DAuth Notices, always CC the following parties on communication regarding DAuth Notices. Without all parties informed, there could be delays in completing this request.

Principal
Principal’s Implementer
Delegate
Delegate’s Implementer

Forms

Particle Delegation of Authority Notice Form (Preferred)

This Delegation of Authority Notice form is designed to work on both Carequality as well as CommonWell QHIN. As many customers are—or in the process of— joining TEFCA as sub-participant through Particle (via CommonWell as the Sponsoring QHIN), we want to ensure they do not have to have duplicative DAuth processes to complies with Carequality (in the short term) as well as on CommonWell (long term migration to TEFCA).

In this form, we've included definitions across both frameworks. Also, we are requesting our customers to respond with the core set of questions found in the Carequality Policy but also complete the additional field from CommonWell.

Alternative Form Submission are accepted by Particle.

Particle will happily accept other Implementer's forms, as long as they have the required set of data to comply with Carequality's forms. For convenience, here are links to the Carequality Forms:

More information on these forms can be located within the Carequality Framework Policies (v. 3.0)

Note: This documentation is accurate as of 5/12/2025, and may be updated by Carequality.

If You Are a Particle Customer, who is a Principal ...

You are likely here to authorize a vendor to querying on the networks on your behalf. See below on how to complete a Delegation Notice so that Particle can list them as a Delegate to your Principal listing.

What to Do:

Make a copy of the Delegation Notice spreadsheet.
- Google Sheet
- XLSX
Fill out sections to the best of your ability.
- Purpose of Use: Currently, you will attest that your vendors is requesting to make delegated requests on your behalf for Treatment, the only permitted exchange at the moment on Carequality. Depending on the range of services this vendor provides, you may want to authorize other purposes of uses.
  - Individual Access is mandatory exchange on TEFCA today. If this is a use case that you would like a vendor to support you in, consider adding this POU.
  - Operations is slated to become mandatory early 2026. If this is a use case that you would like a vendor to support you in, consider adding this POU in anticipation of this exchange purpose.
  - CommonWell has a program for "Bring your Own Trade Partner" which allows specific organization to exchange for POUs which are not yet exchanged for on the network. If you want to be a role model this exchange with one of your vendors, let us know. We can help determine if we can support additional POUs in this program.
- Initiating & Responding vs. Initiating only The intention of this attestation is to ensure all clinical data is made available on the network while ensuring no duplicative data is being pass back on the network. You will be initiating only, if this is a visualization tool (not creating net data) or all the net new clinical data is being returned through an EHR integration.
- Downstream Delegation Complete this attestation, if you believe there is an explicit use case to give the vendor the right to delegate to another vendor to query on your behalf. This is not often seen, so please discuss the use case with your Technical Compliance Lead, if you believe this is something you want to provision.
Some fields will be completed and/or confirmed by others parties:
- Particle (your Implementer) will complete technical details (OID in directory)
- The Delegate’s Implementer will complete technical details (OID in directory)
- The Delegate can support a description about about their software & the delegated treatment request.
- (optional) Discuss with Particle if you'd like to plan to join TEFCA as a sub-participant of Particle through the CommonWell QHIN.
Once this document is reviewed and completed for accuracy with Particle, the Authorized Individual at your Organization can sign the Notice.
Particle will take it from here! Specifically, we'll CCing all correct Parties (Delegates and Delegate's Implementer) for the completed Delegation Notice, and coordinate with the Delegate's Implementer to review for accuracy and completeness.
With all parties signed off, Implementers will complete the technical changes in directory (see Technical Implementation for specification)

Important: If your vendor’s tool is your system to initiate queries, you could be considered a System of the Principal and you may not need a Delegation Notice. Please schedule time with your Technical Compliance Lead, to confirm.

If You Are a Particle Customer, who is a Delegate

If you are likely here to learn how to best educate your customer to understand a Delegation Notice and obtain authorization from them.

What to Do:

Make a copy of the Delegation Notice spreadsheet.
- Google Sheet
- XLSX
Fill out sections to the best of your ability and send to Particle. Some fields will be completed and/or confirmed by others parties:
- Particle (your Implementer) will complete your directory/OID details. We also can look up on the directory about the Principal, specifically finding their OID and their Implementer on the network.
- Here's how to think about talking through these fields with your customer (Principal):
  - Authorized Permitted Purposes: While Treatment is the only exchange purpose that is mandatory on the networks, this form is intended to work for the future when other permitted uses are exchanged. Here's how you should consider a discussion with your customers on additional use cases:
    - Operations for example, is not an active exchange on the networks, but the Operations SOP states it will be mandatory in February 2025. If you currently support your customers in Operational use cases and would like to query networks in the future, please discuss if they'd like to provide authorization now and have them to check the box.
    - Patient Request is a query pattern where individuals can access their own records, or allow entities to query on their behalf. This exchange purpose currently mandatory on TEFCA. If you are interested in participating to access this query pattern on behalf of the Principal, please discuss with Particle.
    - All other Permitted Purposes have not been announced for the date for exchange to commence. So practically speaking, no real plans of action can be made, but depending on your relationship with the Principal org, these boxes can be checked as well.
  - Principal Attestations:
    - Initiator of transactions this field is verifying if the Principals must be already listed on Carequality and/or TEFCA to provide the authority to delegate the authority to query.
    - initiator only-- this field is if the passes back data the delegate's in their system, or if the delegate is only a visualization tool and does generate net new data
    - Downstream Delegation -- this field is if the Principal will allow you, as a Delegate, to work with other vendors to query in their behalf.

Note:

If your software acts as a System of the Principal-- providing the tools for Providers to initiate query request -- you may not need authorization from the Principal. To confirm, please connect with Drew to review your technical workflow and how your product interacts with the Principal’s systems.
If you are unsure whether you are classified as a Delegate, Particle can help verify, referencing your Network Questionnaire and your submitted Exhibit 1. While Particle will check these on a yearly basis, if any information has changed (expanded supported use cases or new product releases) please let Particle know. Please coordinate with your Technical Compliance Lead to update it.

If You Are Another Implementer (Not a Particle Customer)

If you are not a Particle customer, you're likely reaching out to submit a Delegation Notice to Particle, who is acting as the Principal's Implementer.

Please do the following:

If you have a completed form for submission...

You have been collaborating with your customer (Delegate) and Particle's customer (Principal) to complete the DAuth Notice. If you have a submit the signed Notice, please send to Particle at [email protected], ensuring you are CC all parties:

Particle (the Principal’s Implementer)
The Principal’s signatory
The Delegate’s main contact
The Delegate’s Implementer
Particle will respond on thread acknowledging the submission, starting the 5 day SLA review period. If clarifications are needed, we will reply within the same email thread so everyone stays informed. Once approved, technical updates will be reflected in the directory.
Once submitted, we will acknowledge receipt and begin our five-day review timeline.

Common Questions

Please reach out for any other questions, so far, here's a few! We're committed to trust on the network and collaboration between implementers.

Who do I submit a DAuth form to when there are 2 Principal Listings? It's common to have multiple systems of a Principal implemented on the network. If you're unsure who should receive the DAuth, we are happy to have that discussion.
Can we submit a batch review of DAuth Notices before completion? Sure! We want to reduce friction in this process. We would like to support collaboration across Implementers to help consistently explain this process to Principals and reduce the operational burden on them. Please share a spreadsheet of the Principal listings your customers will need to request authorization. We can help educate our customers on the process and the fields being requested from their vendor (Delegate).

If you have questions about which Implementer to contact, please out to [email protected].

If You Are a Prospective Particle Customer

You're probably investigating how Particle manages Delegation of Authority and compliance in comparison to others.

You are in good hands—we pride ourselves on making compliance both practical and effective. We see compliance as a strength, balancing principle with real-world workflows.

During our onboarding and sales process, you will be asked to complete a Network Questionnaire. These questions help us understand your legal organizational structure, technical query workflow, how providers interact with your system, and whether you generate new clinical data.

With information we can:

Prepare an Exhibit 1 (E1) to submit Carequality. This will be reviewed and approved in approximately 1 week.
Determine if you will be a Delegate and need to coordinate authorization from the Principal organization before any queries begin.