Clinical Data Contribution Policy

Use Case

Under HIPAA, the use and disclosure of protected health information (PHI) is permitted for activities related to Treatment, Payment, and Healthcare Operations (TPO). The national EHR networks Zus participates in specifically require an active treatment relationship and satisfaction of data reciprocity.

Operations and payment use cases are not yet supported by the majority of participants on the national networks, and thus are not yet supported for EHR data querying by Zus.


The CommonWell and Carequality networks are built on trust and mutual participation. The organizations that respond to our queries with rich clinical documentation expect to receive similar documentation in turn. We also believe that sharing your clinical data with the network reinforces your credibility as a treating provider that is responsible for your patients’ outcomes, particularly when members of their care teams need to coordinate care.

Zus customers MUST contribute clinical data for every patient they are querying on CommonWell and/or Carequality. Zus will address any nonadherence by a customer through a variety of actions, up to and including suspension of such customer’s ability to query clinical data until adherence is demonstrated. Depending on your care model, you may be best suited to comply with one or more of the following approaches:

  • Clinical encounters: For those patients that are actively being seen for clinical encounters, you must have a complete clinical encounter summary written to Zus within 24 hours of encounter documentation completion. The summary should include key information about the encounter (e.g., provider, location, time / date, diagnosis, type) as well as the clinical notes from the encounter.
  • Care management interactions: If patients are not being actively seen for a full clinical encounter, but are engaging with care management team members operating on behalf of the patient's provider, Zus will accept a lighter set of documentation. This may include phone call notes or updated care plans (e.g., goals, tasks).
  • Referred patients: If patients have been referred to your practice, but have not yet been seen, Zus will accept a more limited set of information until the patient is seen. This may include patient demographics, insurance coverage, the care team that the patient has been referred to, upcoming appointments that have been scheduled for the patient, and patient history that has been provided to your practice as context for the referral.
    We will also be limiting the volume of queries that rely on treatment purpose of use (i.e. CommonWell, Carequality, Surescripts) for this type of relationship. Until a patient is successfully engaged with your program, we will only permit a single broad query to the networks. In addition, we will continue to automatically seek discharge summaries for these patients if they are subscribed to a package that includes ADT and receive any alerts. We are currently working on automating this policy and expect to enforce it by September 1, 2024. In the meantime, we would like to discuss with you how engagement status is evidenced in your workflow to ensure the transition is automated in Zus.

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.

  • On behalf of: If your EMR offers a connection to the CommonWell and/or Carequality networks and contains documentation for all of the patients for whom you are querying these networks, you may leverage this pre-existing connection to directly contribute to the respective Networks.
  • Zus integration: If you use Elation as your EMR, you may leverage our integration to satisfy the requirements. We recommend athenahealth customers leverage the ‘on behalf of’ pathway.
  • 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, C-CDA, and PDF formats through our APIs.

For more information on how to contribute data to the Zus platform, see How Data is Shared, including the section on Responses to EHR Networks.