Draft TEFCA Needs A Lot More Work

TEFCASince the release of the Draft Trusted Exchange Framework and Common Agreement (TEFCA) on January 5th, EHRA volunteers from the Standards and Interoperability, Privacy and Security, and Public Policy Leadership Workgroups have been reviewing and discussing the document. Together, they drafted EHRA’s comments, which were submitted this week to the Office of the National Coordinator for Health IT (ONC).

As EHR developers, we support the goal to provide nationwide interoperability using networks as important building blocks, and believe TEFCA has the potential to dramatically improve interoperability.

However, the draft TEFCA overreaches, neglects important details, and doesn’t consider the practicality or potential unintended consequences of the policy. We strongly recommend that ONC review stakeholder feedback and publish a revised proposed draft for another round of feedback, before finalizing the policy.

The current draft TEFCA lacks specifics, and raises important questions and concerns. For example, how can we utilize existing networks to expand interoperability? How will care-critical network traffic be prioritized? How will testing mechanisms be implemented? How can equitable allocation of the costs associated with data exchange be assured? Should patient consent be treated as site-specific, or centralized and holistic?

EHRA strongly supports efforts to improve interoperability and expand access to data as a means of improving delivery of high-quality healthcare. Much progress has been made to date through various initiatives such as eHealth Exchange, CommonWell Health Alliance, Carequality, and Strategic Health Information Exchange Collaborative (SHIEC) with strong participation by EHRA members.

The approach proposed in the draft TEFCA, however, suggests a drastic change from these solid starting points, with an unrealistically tight timeline. We recommend ONC look to leverage existing investments in interoperability and build upon these successes with close stakeholder collaboration. The efforts in progress between Carequality and CommonWell to connect the respective participants is a prime example of successfully connecting diverse approaches.

While comments on proposed policies of necessity focus on concerns, it’s important to note that there is also much to praise in the draft framework. Among them, we appreciate ONC’s efforts to align TEFCA requirements around the NIST cybersecurity framework, and with HIPAA.

Interoperability is essential to enable data to follow the patient, to assist providers in the coordination of care, and to contribute date to public health authorities, registries and research to enable a learning health system. It’s already making a difference, and EHRA looks forward to continuing to collaborate with fellow stakeholders as the U.S. moves toward more widespread exchange of health data.

We appreciate ONC’s openness to stakeholder feedback on the draft TEFCA and are hopeful that we’ll have another opportunity to share our expertise.  

Read our full TEFCA comments here.

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