August 27, 2026: Network policy updates

Multiple TEFCA SOPs were updated in August 2026 to modify who can submit queries on for TEFCA Required Treatment, and under what circumstances. We expect behavior on Carequality to orient around these SOPs as well. We have updated our Clinical Data Contribution Policy and vetting processes to reflect these changes.

• Treatment XP SOP v2.0 makes the following adjustments:
  • Every TEFCA Required Treatment (T-TRTMNT) query must connect to a documented present or planned clinical event for that specific patient. The SOP provides a list of qualifying events.
  • Attribution is explicitly supported as a basis for querying: where a care model contractually establishes your clinical accountability for a patient, that relationship qualifies even if you have not had a patient-initiated encounter yet.
  • Certain query patterns are explicitly excluded, including patients who declined or ended a care relationship, patients you no longer have clinical accountability for, bulk queries without a per-patient event, repeat queries without a new event, and anything preparatory to research.
• Reciprocity requirements now align with USCDI v3.1 instead of USCDI v1 (Exchange Purposes SOP v5.1).
• Any vetted HIPAA Covered Entity (CE) Health Care Provider can now query under T-TRTMNT, along with its Delegates. However, providers must provide evidence of a claim or other HIPAA-covered transaction in order to demonstrate that they are a CE (XP Vetting Process v2.0).
• CEs must now provide their Federal Employer Identification Number (FEIN) in order to be listed on TEFCA (RCE Directory Service Requirements Policy SOP v1.1).

Treatment & Clinical Data Contribution

We have updated our Clinical Data Contribution Policy to align with the Treatment SOP linked above; what to know:

• Most customers are already align Chart Build queries to specific clinical events and provide associated clinical documentation to the networks. Zus's Intelligent Refresh logic also ties monitoring queries to specific clinical events.
• We will be reaching out to customers with the following use cases:
  • If you run periodic or one-off queries to check for open care gaps, you should document the care management need in the data returned to Zus.
  • If you query for newly attributed patients, you should document the attribution and your planned or completed outreach to the patient.
• The USCDI v3.1 requirement applies as follows:
  • If you are providing documentation from a certified EMR, it should already be consistent with the updated requirement
  • If you provide documentation from a homegrown system, we recommend reviewing whether you maintain and could supply any of these additional data classes:
    • Health Status/Assessments — Functional Status, Disability Status, Mental/Cognitive Status, Pregnancy Status
    • Clinical Tests — non-imaging, non-lab tests (ECG, visual acuity, GXT)
    • Diagnostic Imaging — Diagnostic Imaging Test, Diagnostic Imaging Report
    • Health Insurance Information — Coverage Status, Coverage Type, Relationship to Subscriber, Member ID, Subscriber ID, Group ID, Payer ID
    • Social Determinants of Health (SDOH) data as part of Problems/Health Concerns, Assessments, Goals, and Interventions

Contribution pathways, accepted formats, and our monitoring and enforcement process are unchanged.

Vetting Process Updates

We have updated our vetting process to align with TEFCA requirements. Going forward, we will ask customers onboarding individual practices as Principals to provide redacted evidence of a claim or other HIPAA-covered transaction, as well as an FEIN.

There have been no changes to Delegation of Authority processes.

Questions?

Please reach out to your Zus contact if you have any questions about these changes and how they impact you.