by adgrooms on January 9, 2020

Healthcare interoperability still has gaps to bridge, and many different entities are trying to come up with solutions. We talked about two companies that are trying to fill the gaps in our last post. Both have networks that entities can plug into to exchange data, but neither was a comprehensive solution that provides access to all entities. The hard part is organizing all of the solutions in a way that actually makes complete interoperability of the healthcare system possible. A few years ago, congress instructed the Office of the National Coordinator for Health Information Technology (ONC)to develop a framework that connects the health information exchange networks. This has prompted the the ONC to propose rules guiding interoperability called TEFCA (Trusted Exchange Framework and Common Agreement).

There are currently regional, community, and organizational health information exchanges that organizations can join to exchange information. TEFCA aims to provide one network or on-ramp to link all of these existing networks, creating a network of networks. This means current exchanges will be able to exist as they are, but providers will easily be able to get information to and from entities that belong to separate exchange. This should allow patient data to go instantly where the patient is located, without the current roadblocks, ultimately improving quality of care and outcomes. TEFCA is intended to be technical guidance, but it also aims to make the legal path easier for providers to exchange patient health information.

TEFCA is actually two parts, the Trusted Exchange Framework (TEF) and the Common Agreement (CA). TEF is a non-binding set of principles to that health information exchanges should follow to enable better exchange of data. These include: "standardization; transparency; cooperation and non-discrimination; privacy, security, and patient safety; access; and data driven accountability". The Common Agreement (CA) will be a determined set of terms and conditions for a data sharing agreement. This is intended to standardize trust agreements where in the past there has been variance and complexity. It will provide policies and expectations as well as a technical framework to be determined by working with a recognised coordinating entity (RCE), a selected private entity that will receive funding from the ONC.

The recognised coordinating entity (RCE) was recently announced as the Sequoia Project, a non-profit independent advocacy group promoting health information exchange. A quick background on Sequoia Project: It was formed in 2012 when the ONC transitioned its Nationwide Health Information Network to the private sector now known as eHealth Exchange. It is the largest health data network. Sequoia project also started Carequality, a collaborative effort to establish a consensus for technical standards and best practices for interoperability. It has a board and members that includes EHR vendors, payors, healthcare institutions, and other advocacy groups. Given the history with the ONC and its work on interoperability initiatives, Sequoia Project is not a surprising choice to be RCE.

As RCE, Sequoia Project will be developing the Common Agreement, taking input from stakeholders, monitoring the qualified health information exchanges, and developing a process for dealing with non-compliance. They will provide a process to keep the common agreement updated as needed and working with the ONC to ensure the framework is implemented and runs smoothly. They will also be in charge of overseeing and approving health information networks to become qualified to participate in the comprehensive network once they implement the requirements of the technical agreement.

TEFCA Overview

That is the basic overview of the current state of TEFCA. The initial TEFCA draft was left with incomplete details to let the Sequoia Project and the ONC to gather more ideas from industry for creating a final rule. There was a feedback session on Dec 11 to gather information for the next draft. This collaborative process is currently ongoing with no information on the release of the next draft. It will be interesting to see how the private companies we wrote about in our last post will be included in the future of TEFCA. It will also be interesting to see how Sequoia Project's existing eHealth Exchange and Carequality initiatives will be a part of this. There are many unanswered questions we have.

We will closely follow developments and look further into the details of the rule in future posts. You can read all of TEFCA Draft 2 here.