Clinical Data Contribution Policy

Updated March 23, 2026

Carequality, CommonWell, and TEFCA rely on a give-to-get model to function. Organizations that query data on a patient must also contribute their own clinical records for that patient. As of December 31, 2024, 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 v1.

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.

We recommend contributing the following types of data based on your level of engagement with the patient:

Relationship with Patient	Newly attributed patients that are not yet engaged	Actively outreaching, but no clinical encounters	Have had 1+ clinical encounters
Data to contribute	Care Plan with plans for engaging patient by a specific date and information about the care model	Details on each outreach attempt If patient schedules appointment, write the appointment to Zus	Encounter summary, historical encounter and chart information
When should my integration contribute data?	When you query data or enroll the patient	Within 24 hours of each outreach attempt or of scheduling each appointment	Within 24 hours of closing an encounter
(For active implementation customers only) How often should I supply data if I have a manual process?	When you query data or enroll the patient	Once a week	Once a week
What formats are acceptable?	FHIR PDF or CDA Flat file	FHIR (outreach, appointment) PDF or CDA Flat file	CDA (recommended) PDF FHIR

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.

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, 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.