TEFCA Signals Progress, With Work To Be Done

By EHRA Public Policy Leadership Workgroup

After a journey more than four years in the making, the Office of the National Coordinator for Health IT (ONC) and The Sequoia Project achieved a major milestone in the advancement of nationwide health information exchange: the publication of the Trusted Exchange Framework and Common Agreement (TEFCA) v1.0. ONC and The Sequoia Project have demonstrated their commitment to incorporating input from stakeholders across the industry, which created a process that produced significant improvements with each draft publication. We applaud the significant efforts undertaken by ONC and The Sequoia Project to collaborate with industry interoperability experts and create a framework that incorporates key principles of trusted exchange, like reciprocity, as well as a technical approach that leverages commonly adopted standards. 

For well over a decade, members of the Electronic Health Record Association (EHRA) have invested substantially in advancing the data sharing capabilities of the health IT systems used by healthcare organizations across the country with the belief that doing so will improve the quality and efficiency of health care. It is our sincere hope that TEFCA will continue to build on those investments for the benefit of patients.  

While ONC and The Sequoia Project have passed a significant milestone in working with the industry to publish TEFCA v1.0, much work remains to be done to realize the vision of TEFCA being a “single on-ramp” to connectivity. Member companies acknowledge the potential of engagement with TEFCA (as a Participant/Subparticipant or even as a QHIN), but important implementation details still need to be settled before any entity can confidently move forward. Specifically, ONC and The Sequoia Project must expedite the publication of remaining Standard Operating Procedures, Fee Schedules, and other important documentation (such as the QHIN Application and Onboarding Requirements and expected Service Level Agreements) in order for all stakeholders to have a complete picture of the framework’s expectations. Development of a more detailed process for onboarding and transition (for example, how participation in document exchange under Carequality and transitioning to document exchange under TEF for a provider), would also help ease concerns about how onboarding to the new TEFCA network would not disrupt existing exchange, since exchange partners may for some time operate under different frameworks for the same exchange use case(s). Having a full picture of what groups are signing up for is an essential prerequisite to finalizing a decision to onboard.

We also anticipate that ongoing (albeit smaller) revisions and clarifications will be needed to the Common Agreement, SOPs, and QHIN Technical Framework through the initial wave of QHINs onboarding as the rubber begins to meet the road. Continuing the welcome precedent set in the formation of TEFCA, ONC, and The Sequoia Project should continue to collaborate closely with stakeholders across the health ecosystem during the implementation phase by establishing a workgroup of aspiring Qualified Health Information Networks, Participants, and Subparticipants. This workgroup could serve as a venue for those groups to seek definitive clarifications during the implementation process, also allowing for needed continued iteration. 

Finally, ONC and The Sequoia Project should continue to develop the value proposition for organizations to join TEFCA. While we strongly agree with the approach of starting with Treatment and Individual Access Services as the required exchange purposes to avoid overwhelming groups that join in the first wave, a clear work plan should be published to clarify which additional exchange purposes will be added through a measured and predictable schedule over time; such a work plan should include timelines for creating mature implementation guides for each sub-use case within the contemplated future exchange purposes, as well as a roadmap to requiring its support. Doing this now will help potential Participants and Subparticipants understand that joining early will help set them on a path to exchange for use cases beyond treatment.

In ONC’s announcement, Micky Tripathi, Ph.D., national coordinator for health information technology, said, “Simplified nationwide connectivity for providers, health plans, individuals, and public health is finally within reach.” We agree. Let’s keep working together closely through these critical next steps to make this vision a reality.

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