Delegation of Authority

In both Carequality and TEFCA, the authority to query for Treatment belongs to Covered Entity (CE) providers, as discussed here. Providers can delegate authority to other Business Associates (BAs) to query on their behalf without contributing additional data to the networks.

Terminology you might encounter

• Principal: The CE provider's listing on the networks that contributes data from their EMR or other system of record. A CE provider might have multiple Principal listings if they have multiple systems of record.
• Principal's implementer: The EMR or on-ramp that connects this provider to the network, manages their directory listing, and contributes clinical data (e.g., Epic, Surescripts, eClinicalWorks, in some cases Zus).
• Delegate: A BA to whom the Principal CE has delegated authority to query. The CE can attest that they are contributing clinical data through their Principal listing, and that the BA has no additional information to contribute.

Delegation process

In order to receive a Delegation of Authority from a Principal, a Business Associate must:

• Ask Zus to generate a Delegation Notice (templates below)
• Send that Delegation Notice to the Principal for signature (Zus can send these as DocuSigns upon request)
• Send the signed notice back to Zus

Zus will share the Delegation Notice with the Principal's Implementer, cc'ing the Business Associate and the Principal.

The Principal's Implementer must accept and activate the Delegation before we can proceed with queries. They are required to process the listing and accept it or ask for more information within 5 business days. They may reach out to the Principal to confirm the relationship and the use case for querying.

Who does this process apply to?

• Zus customers who are BAs serving one or more Provider CEs must follow this process and get a signed Delegation Notice from each Provider
• Zus CE customers who have an existing EMR listing that contributes data for all their patients may delegate authority to Zus to query on their behalf without needing additional reciprocity

What if I'm a Business Associate with customers who aren't listed on the network?

Zus will need to work with you to get those customers listed on the networks as new Principal Covered Entities. This will require:

• Conducting a Use Case Review with those Principals to ensure that they meet network requirements to be listed and onboarded
• Having those Principals accept flowdown Terms of Service from the networks and Zus
• Setting up technical integrations to contribute data to the networks for those Principals

Delegation notice templates

• Carequality
• Combined Carequality & TEFCA
  • If the Principal has an active listing on both Carequality and TEFCA, Zus recommends that they sign the combined form to avoid repeating the process a second time down the road