Shareback Requirements

Shareback obligations vary by organization type, contractual terms, and participation in networks such as Carequality, CommonWell, eHEX, and TEFCA. These expectations uphold reciprocity and support the completeness of patient records available across the ecosystem.

Shareback Methods

Health Gorilla supports several approaches for contributing clinical data.

Organizations can:

• Submit structured FHIR resources such as Observation, Condition, Encounter, DocumentReference, Immunization, and MedicationRequest
• Upload structured C-CDA documents when multi-section or encounter-summary formats are available
• Contribute diagnostic orders and results through the Lab Network, which automatically generates FHIR Observation and DocumentReference resources

Unstructured documents such as PDFs are accepted only in limited situations and should not serve as a primary contribution method because they cannot be normalized or used reliably in downstream workflows and may not meet network reciprocity expectations.

Reciprocity

Nationwide exchange operates on the principle of reciprocity, meaning organizations that retrieve data are also expected to share back information that is clinically meaningful, current, and standards-compliant.

Consistent shareback helps:

• Maintain eligibility for network participation
• Improve the completeness of patient histories for shared patients
• Support care coordination and clinical decision-making
• Demonstrate compliance with TEFCA and related interoperability rules

Health Gorilla enforces reciprocity requirements consistent with the underlying exchange frameworks.

Compliance and Governance

Data sharing is governed by national interoperability frameworks and Health Gorilla’s QHIN policies. Participation requires adherence to the following rules:

• Permitted purpose of use: Data must be exchanged only for a valid purpose of use—typically treatment—and queries outside that scope are not allowed.
• Reciprocity obligations: Organizations that retrieve data must also share back clinically meaningful information to maintain network access.
• Minimum data standards: Contributed records must meet required content and vocabulary expectations, including SNOMED CT, LOINC, and RxNorm where applicable.
• Provenance requirements: Each contributed record must include source, author, and encounter context to support auditability and downstream clinical use.
• Probing restrictions: Participants may not test for the existence of records before validating identity and purpose of use; all exchange must occur through permitted workflows.

Health Gorilla validates, normalizes, and audits all shared data to support compliance with TEFCA, Carequality, CommonWell, and other national exchange requirements.

Data Handling

All shared data moves through Health Gorilla’s standard processing pipeline to ensure shared data is accurate, consistent, and traceable across the ecosystem.

• Validation against FHIR profiles and industry vocabularies
• Normalization into consistent FHIR structures
• Deduplication of overlapping records
• Provenance tagging and audit logging
• Routing through national network trust frameworks

Best Practices for Shareback

To support high-quality shareback and meet reciprocity expectations, Health Gorilla recommends:

• Use structured FHIR resources whenever possible
• Share complete encounter-level information, not partial subsets
• Apply standard terminologies (LOINC, SNOMED CT, RxNorm) for diagnoses, labs, and medications
• Include stable patient identifiers (such as local MRNs or internal IDs) to support accurate matching
• Avoid contributing PDFs unless necessary
• Review contribution activity periodically to ensure records are accepted and acknowledged by network partners

For an example of data sharing, go to Data Flows.