Yes. A Medicare home health agency can query the national exchange networks for a patient it is treating, and most of the country’s hospitals are on the other end. It cannot do it by signing up with Carequality or CommonWell, because neither takes providers directly, and there are two conditions that most explanations leave out. This is the answer as the networks’ own policies give it in 2026.
The short version
- Not directly. An agency reaches the networks through its EHR vendor or through an intermediary that is already connected.
- For treatment. The agency is a health care provider under HIPAA, and the networks let a provider that is actually treating the patient query for that treatment. A referral in hand is what makes it treatment.
- With something owed in return. Carequality expects an organization that queries for treatment to answer treatment queries too.
- With no guarantee of what comes back. Responders are expected to answer, and the content is a summary, not the chart.
Nobody joins Carequality
Carequality is a framework, not a network, and its FAQ says so: “Carequality is not an intermediary.” The organizations that sign with it are implementers: EHR vendors, exchanges and record services. Everyone else is a “Carequality Connection”, an organization that participates through one implementer, is “properly listed in the Carequality Directory” and is bound by the connection terms. Per the FAQ, “Only Carequality Connections (CCs) can initiate a query”, and provider organizations “do not pay anything to Carequality”; whatever an agency pays, it pays its vendor.
So the practical question is never “can we join” but “is our vendor an implementer, and has it turned querying on for us”. One more fact narrows the field: since November 2025 Carequality has been “suspending onboarding of new Implementers”. An agency can still become a connection of an existing implementer. A vendor that is not already in cannot get in.
CommonWell works the same way from the agency’s side. Vendors and intermediaries join as members and build its services into their products; CommonWell describes its users as “ranging from large hospital systems to home care providers and primary care physician offices”. It has been a Carequality implementer since 2018, so a product on CommonWell reaches Carequality’s participants as well, and it became a Qualified Health Information Network under TEFCA in 2024.
Why a home health agency qualifies
Start with HIPAA, because the networks do. A “health care provider” under 45 CFR 160.103 includes a provider of services as Medicare defines it, and the Medicare statute’s list reads “skilled nursing facility, comprehensive outpatient rehabilitation facility, home health agency, hospice program”. Treatment, under 164.501, includes “the referral of a patient for health care from one health care provider to another.” And under 164.506(c)(2), “A covered entity may disclose protected health information for treatment activities of a health care provider.” A hospital may send its records to the agency taking its patient home, without the patient’s authorization. That is the treatment purpose of use.
Carequality adopts that definition. Its framework policies, version 4.0 of May 2026, list eight permitted purposes and use HIPAA’s meaning for treatment. To assert it, an organization shows an organizational NPI or state licensure, and the policy adds a plain test: “organizations claiming the Treatment Permitted Purpose must actually be providing treatment”. The type of organization asking is not a factor. Neither Carequality nor TEFCA names home health agencies as eligible in so many words; eligibility follows from being a licensed provider treating the patient.
The caution in Carequality’s own text
The same policy document contains a sentence every agency should read. In a passage about purposes other than treatment, it lists “queries by home health services in support of intake processes” among activities that could arguably be health care operations instead. Responders do not have to answer operations queries.
The line is the referral. An agency that has accepted a patient, or holds a referral and is preparing the start of care, is treating. An agency running queries on leads to decide whether to take them is doing something else, and Carequality has shown it will act on the difference: in an October 2024 dispute resolution it found that one implementer “inappropriately claimed a Treatment Permitted Purpose for entities” that were not treating, and a connection inactivated for “asserting an inaccurate Permitted Purpose” goes on a restricted list. Query for the patients you are admitting, when you are admitting them.
TEFCA says it more precisely
TEFCA, the federal framework, now has eleven designated networks: CommonWell, eClinicalWorks, eHealth Exchange, Epic Nexus, Health Gorilla, Kno2, KONZA, MedAllies, Netsmart, Oracle Health and Surescripts. Its treatment rules were rewritten in an operating procedure effective August 3, 2026, and they are the clearest statement anywhere of when a post-acute provider may ask.
There are two treatment codes. The broad one is open to “Health Care Providers and their Delegates”, and nobody is required to answer it. The second is the one that matters: “A vetted Covered Entity Health Care Provider or its Delegate” may use it for a query “relating to a documented present or planned clinical event for an Individual”, and for that code a node “operated by or associated with a Health Care Provider or its Delegate MUST Respond.”
The procedure’s examples of a clinical event could have been written for home health: “Receipt of a referral by the Querying Health Care Provider”, a query “in preparation for or following a transition of care for the Individual”, notification of a hospital discharge, receipt of an order, medication reconciliation. The referral examples do not even require that the patient has already chosen the agency. The limits are the mirror image: no querying a patient who declined care, no bulk queries unconnected to clinical events, and each query carries the provider’s NPI and a date range.
Getting onto the vetted list takes a sponsor. A QHIN submits the provider, and the other QHINs have at least five business days to object.
What you owe: the reciprocity rule
This is the condition most often left out. Carequality’s FAQ: an organization that queries for treatment “MUST also play the role of Query Responder for the Treatment purpose, unless an exception applies”, and “There is no exception for ‘pilots’ or ‘demonstration periods.’”
The exceptions are narrow: a provider with no electronic clinical information, an emergency medical service, one barred by law, and a delegate arrangement in which the agency attests that what it obtains is shared back through its own identified system. An agency with an EHR does not escape because the EHR cannot respond; the policy says in terms that this “does NOT qualify as having no clinical information for response”.
For an agency this means one question to put to any vendor or intermediary before signing: when we query through you, how is our obligation to respond met? There should be a specific answer. The paperwork also changed: since May 2025 Carequality requires a delegation of authority from the provider to whoever queries for it, and TEFCA requires a delegation notice. A business associate agreement alone is no longer the whole of it.
What comes back
Expect summaries. Carequality’s policy says “responding organizations should return patient summary and/or encounter summaries, as appropriate”, in the C-CDA format, and that a responder “is strongly encouraged to provide information in response to queries for Treatment”, subject to law and its own access policies. Under TEFCA a required response covers the standard national data set the responder maintains. Neither promises the full chart, and no published figure says how often the discharge summary itself is in what returns.
Coverage is wide and not total. Epic said in 2024 that Carequality “connects more than 70% of U.S. hospitals, 50,000+ clinics, and more than 600,000 care providers”, and that all of its customers participate. Carequality reports “over 1.2 billion clinical documents every month”. A hospital outside the frameworks still means a portal or a fax.
Which home health systems can do it
Fewer vendor pages say “query” than you would expect, and only what a vendor’s own page says is listed here.
| Vendor | What its own page says |
|---|---|
| MatrixCare | Home health and hospice product listed by CommonWell; “Through CommonWell Health Alliance, providers also have access to Carequality”. Describes intake teams retrieving documents from prior settings |
| Kno2 | Carequality implementer and designated QHIN; “allows access to electronically query records and retrieve patient information on demand”, including through a web interface without an EHR integration |
| WellSky | CommonWell member; “WellSky selected Kno2” as its QHIN in January 2025. The pages do not describe the home health user’s query workflow |
| Netsmart | Carequality implementer; designated a QHIN in August 2025. Home health availability is not stated on the release |
| Axxess | Axxess Exchange is “Powered by” Kno2. The page does not say a user can query hospitals |
If your system is not on the list, that is not a finding about your system; it means its public pages do not say. Ask the vendor two things: can a user search for and retrieve a patient’s outside records today, and is the agency listed in the Carequality directory.
Why it still feels like nobody does this
Because the data on home health exchange stops in 2017. The newest federal survey that covers home health agencies found that 78 percent had an EHR and 36 percent could integrate outside information into it; nothing newer has been published. The hospital side is current and not encouraging: in 2023, “only 16% of hospitals reported sending summary of care records to most or all long-term/post-acute care providers”. Hospitals do not push to home health. The agency that wants the record has to pull it.
That is the argument for the query. The referral packet is what the hospital chose to send. A query asks every organization on the network what it holds, and it runs in minutes against the 48 hours to the initial visit. Hospital records before the start of care compares the routes, and EpicCare Link versus one network query covers the portal alternative.
Vivlio is one of the intermediaries: CommonWell lists it among its connectors. For a home health agency it runs the query at referral, for treatment, and returns what comes back organized for the admitting nurse: the discharge summary, the medications, the diagnoses, the recent encounters. If your EHR can already do this, use it. If it cannot, or it returns a stack of documents nobody has time to read before the visit, that is the gap we fill.
