Clinical Data Contribution Policy

Updated August 27, 2026

Network Requirements

Carequality, CommonWell, and TEFCA rely on a give-to-get model to function. Organizations that request data on a patient must also contribute their own clinical records for that patient – other providers treating the same patient rely on those records to provide high-quality care.

TEFCA specifically requires that organizations contribute all treatment records that they maintain on patients they query, as scoped by the data elements listed in USCDI v3.1. It also requires that every query to the networks be associated with a documented clinical event, including queries for ongoing care management. The table below describes how your organization can map clinical events recognized by TEFCA to data contributions.

Before you begin enrolling or querying patients, you must have an integration in place to write this data to Zus (or directly back to the network via your EMR). If you are actively implementing Zus, we are happy to work with you to load records manually in the interim; in these instances, we will work with you to load historical records before beginning queries and you ongoing records on a weekly basis.

What to Contribute

Event triggering a network queryData to contributeWhen to contribute*
All customers
Appointment with the patientEncounter summary, historical encounter and chart informationWithin 24 hours of closing an encounter
Other sync or async interaction with the patient (eg chat, refill request)Record of interaction (eg as a virtual encounter)Within 24 hours of the interaction
Receipt of referral, order, prescription, or consultation requestAny data you add to the patient record related to this eventWithin 24 hours of information being documented
VBC / ongoing monitoring
Attribution of a patientInformation about the care model, and care plan with plans for engaging patient by a specific date or record of outreach that has already happened. (eg outreach, appointment)When you query data or enroll the patient
Receipt of an ADT alert or other transition of care (eg via Zus Intelligent Refresh)Any data you add to the patient chart related to this eventWithin 24 hours of information being documented
Determination of a care management or care coordination need (eg periodic check for open care gaps)Record of care management need in care planWhen you query data or after you evaluate the care gap

*For customers in active implementation, Zus can support a manual load on a weekly basis.

Data Formats & Contribution Paths

We understand that writing this data may require an effort from your technical teams; as such, we are offering a number of pathways to help alleviate this burden.

  • Initiator-only Delegate listing: If your EMR offers a connection to CommonWell, Carequality, and eventually the TEFCA QHINs, and contains documentation for all of the patients you are querying, you can leverage this pre-existing connection to directly contribute data and set up your Zus connection as a “initiator only Delegate” listing. We recommend athenahealth customers leverage this pathway if every patient being queried is documented within athena.
    • Responder Delegate listing: If you are querying patients who are not documented in your EMR yet but are documented in a supplemental system (e.g., a care management tool), you should supply data from this system to Zus via a direct write or flat file ingestion service. This guidance typically applies to newly attributed patients or patients you are actively outreaching to that have no clinical encounters yet.
  • Zus integration: If you use Elation, Healthie, or Canvas as your EMR, you can leverage our integration to satisfy the requirements.
  • Direct write: Customers that do not have a viable EMR integration option must contribute data directly to the Zus Platform. We can accept data in FHIR (outreach, appointment), C-CDA, and PDF formats through our APIs.
  • Services: Zus can ingest flat files from your system, transform the data, and write it to our APIs. Our Customer Success team can provide specs and (if applicable) services pricing for this work.

Monitoring & Enforcement

Zus conducts ongoing monitoring of compliance with this policy. If your integration has broken or stopped supplying records, we will:

  • Reach out and notify you
  • Provide a 5-business-day window to resume supplying records, either manually or via an integration
  • After 5 business days, we will disable EMR network querying customers who have not resumed writes until those integrations are restored. Patient history jobs you execute (or that Zus executes on your behalf) for chart builds or monitoring will skip CommonWell and Carequality during this time. You will retain access to data we have previously retrieved for you.

Did this page help you?