An Analysis of Legal Considerations for Sharing Data Through Community Information Exchanges Q&A
May 13, 2026
Overview
The recently released Journal of Law, Medicine & Ethics supplemental issue features articles authored by presenters at the 2025 Public Health Law Conference in Seattle, Washington. Stephen Murphy, Director, Meghan Mead, Deputy Director, and Emma Kaeser, Senior Attorney, Network for Public Health Law—Mid-States Region, co-authored the article, “An Analysis of Legal Considerations for Sharing Data Through Community Information Exchanges.” In the following Q&A, Stephen, Meghan, and Emma discuss the article and how it addresses a critical public health issue.
Q: Why is this topic so critical right now?
We know there is ample evidence that health outcomes are shaped by social conditions, such as access to healthy food, housing, employment, and transportation. Improving an individual’s health, and addressing health inequities, may require ensuring that they not only receive necessary medical care but also, for example, that they have access to healthy food and reliable transportation to travel to appointments and pick up medication.
Ideally, health and social care reinforce one another and so create conditions in which people can live healthy, thriving lives. But health and social care are often fragmented; these systems, distinct from each other across numerous measures, have historically operated separately, failing to communicate and coordinate on a systematic basis.
Recognizing the potential of integrated cross-sector care, the health and social services fields are increasingly exploring opportunities to improve coordination of their efforts to serve people with health and health-related social needs.
Amid this growing interest in the integration of health and social care, communities across the United States have explored development of Community Information Exchanges (CIEs). CIEs are community-governed systems that facilitate data sharing among local health and social services providers and community-based organizations to promote holistic and coordinated care.
While CIEs and similar initiatives have the potential to promote holistic, coordinated care for people with health and health-related social needs, their use poses challenges from a legal standpoint, as CIEs implicate a host of legal issues related to privacy law compliance, consent models, and legal agreements.
Q: How does your article address the issues raised by CIEs?
Drawing from lessons learned developing a CIE legal framework, our article explores considerations and best practices for navigating these issues. First, in the article we provide further background, describing common goals and features of CIEs and expanding on the legal and policy challenges that CIEs raise. We then address general considerations for development of a legal framework and examine legal questions related to two primary components of a CIE legal framework: consent models and compliance with the Health Insurance Portability and Accountability Act.
Q. How do CIE’s help address health disparities and advance health equity?
Access to resources is grossly uneven, with people of color, people with low or no income, people with disabilities, and other systemically marginalized groups disproportionately experiencing health-related social needs driven by structural racism and other forms of oppression. CIEs and similar initiatives can work to advance health equity by ensuring that those who are systemically underserved have access to needed services and support, fostering autonomy and dignity in the process.
While CIEs present some novel challenges, the considerations and best practices outlined in the article can guide legal counsel. With a strong legal framework, participating entities, organizations, and community members have the foundation for trusted and accountable information sharing central to CIEs. Once the legal framework is in place, CIEs provide a pathway to unite cross-sector partners through information sharing that is community driven and equity centered.
The Network promotes public health and health equity through non-partisan educational resources and technical assistance. These materials are provided solely for educational purposes and do not constitute legal advice. The Network’s provision of these materials does not create an attorney-client relationship with you or any other person and is subject to the Network’s Disclaimer. Support for the Network is provided by the Robert Wood Johnson Foundation (RWJF). The views expressed in this post do not represent the views of (and should not be attributed to) RWJF.
The Network promotes public health and health equity through non-partisan educational resources and technical assistance. These materials are provided solely for educational purposes and do not constitute legal advice. The Network’s provision of these materials does not create an attorney-client relationship with you or any other person and is subject to the Network’s Disclaimer. Support for the Network is provided by the Robert Wood Johnson Foundation (RWJF). The views expressed in this post do not represent the views of (and should not be attributed to) RWJF.