HIMSS engaged in an open and deliberative process to construct its comments on the Office of the National Coordinator for Health IT’s draft guidance on the Trusted Exchange Framework and Common Agreement (TEFCA). We utilized the workgroup that was created to activate our Interoperability Call to Action to develop our comment letter and act as a sounding board for feedback that we received from other stakeholder organizations where we collaborate.
The thrust of our comments focus on a few themes:
• Create a Framework that builds on the successes underway across the community and capitalizes on the advances that we have made in facilitating nationwide interoperability
• Move forward with TEFCA implementation, but adjust the timelines and expectations
• Ensure that the appropriate information/resources are available across the community to enable exchange
Overall, HIMSS expressed support for the concept behind TEFCA and the effort to minimize the point-to-point interfaces required to broadly exchange data across the care continuum. ONC’s work is placing individuals at the center of their care and ensuring providers have the ability to securely access and use health information from different sources.
The Framework that HIMSS is advocating for builds on the significant momentum underway across the community—and attempts to maintain this positive trajectory by not asking current exchange entities to make significant adjustments to their workplans to become Qualified Health Information Networks (QHINs) under TEFCA. We want ONC to relax its QHIN requirements and more closely align any directives with current exchange structures to minimize disruption and capitalize on what’s working in nationwide data exchange.
We also highlighted what was working related to Prescription Drug Monitoring Programs (PDMPs) and exchange network coordination as well as with opioid-specific advances. In our comment letter, HIMSS held up the state of Nebraska and the convergence of state law (Nebraska was the first state to require reporting of all dispensed prescription drugs to the PDMP and requires that the Nebraska Health Information Initiative’s exchange and the PDMP are hosted on the same platform) and technology advances to describe the model practices applicable to the rest of the nation. Nebraska is also advancing efforts to prevent and mitigate opioid overdoses and related deaths in the state.
In terms of a TEFCA phase-in, HIMSS asked ONC to create a strong Recognized Coordinating Entity (RCE) that acts as the engine fueling the development and adoption of the entire Framework. We see the RCE facilitating even greater partnerships and collaborations across all the modified QHIN entities and being empowered to monitor the market to ensure that there is more oversight than exists today. Moreover, many of the implementation timelines in the framework guidance and the US Core Data for Interoperability (USCDI) will be challenging to implement. HIMSS wants the RCE to work with all the exchange entities to specify the “rules of the road” for participation under the RCE structure as well as what the timelines should be in moving toward adoption of a Common Agreement.
HIMSS also questioned what the default set of data should be for responses to broadcast queries. The USCDI proposed 22 data classes for exchange, but HIMSS recommended that the requestor of the patient information decide what they would like to receive and what fits into his or her workflow. HIMSS envisions building up to routinely exchanging all 22 data classes, but as we phase-in TEFCA, ONC should consider a smaller sharing set to start.
The community also needs additional information and resources in order for providers as well as individuals to want to play a part in the entire TEFCA effort. The cost to participate will be a significant factor, so more information on fees and other associated expenses that potential partners may incur will be welcomed by the community. Privacy and security is a major consideration, and the integrity of the information being exchanged must be assured as well. Whether an individual granted consent to share his or her data is also a big issue, and we asked ONC for more clarity around how exchange entities can ensure that that consent was captured.
The issue of patient matching for exchange participants could also be challenging and requires more information to be generated to educate the community. HIMSS would like to build out tools that networks could use to learn about different matching approaches and algorithms and the results of the benchmarking evaluations being performed—all this information would lead to ensuring that patients are accurately identified and privacy is protected.
Overall, HIMSS wants to use the appropriate regulatory policy levers to support the adoption and use of the Framework. ONC is currently developing the 21st Century Cures Act Information Blocking provisions—our letter encourages ONC and the HHS Office of the Inspector General to leverage the Framework in the upcoming proposed regulation to incentivize more participants to share data in alignment with the Framework.
HIMSS will be reviewing other public responses to the TEFCA guidance as the process moves forward and we receive the information blocking proposed rule. If you have thoughts or further ideas for consideration, please feel free to reach out to me at firstname.lastname@example.org.