HIMSS Submits Comments on the TEFCA Draft QTF

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On Friday, Sept. 17, 2021, HIMSS provided written comments on the Trusted Exchange Framework and Common Agreement (TEFCA) Draft Qualified Health Information Network (QHIN) Technical Framework (QTF).

In the comment letter, HIMSS expressed appreciation for ONC’s work to create TEFCA and establish a floor of universal interoperability across the U.S. and thanked The Sequoia Project for its ongoing work as the Recognized Coordinating Entity (RCE) and leadership on drafting QTF.

The comments focused on several points:

TEFCA is a helpful tool to utilize on the journey to nationwide interoperability, but the community needs more specifics to buy-in

As the U.S. implements the interoperability regulations from ONC and CMS and moves closer to ubiquitous data exchange across the care continuum, HIMSS wants to ensure that the community has TEFCA and the broader interoperability that it enables as an available tool. HIMSS stated that ONC and The Sequoia Project should move forward with their planned public engagement webinars on TEFCA in the near-term and use them as an opportunity to build understanding and interest from all potential participants. The aggressive timeline that ONC and The Sequoia Project have presented to operationalize TEFCA in the first quarter (Q1) of calendar year 2022 will require broad community buy-in to meet its goal, and more public education will serve to support it.

Building TEFCA on a foundation of IHE Profiles is the right place to begin

ONC and The Sequoia Project should be commended for building the TEFCA Network on existing infrastructure and leveraging Integrating the Healthcare Enterprise (IHE) Profiles, as well as planning for the conversion of IHE Profiles to the Health Level Seven International (HL7®) Fast Healthcare Interoperability Resources (FHIR®) Standard in the future. IHE Profiles provide the backbone to much of the health data exchange occurring across the health ecosystem today. The IHE Profiles identified in QTF are open standards and are working successfully across the community—HIMSS indicated that they are the appropriate standards to use from the onset as QTF seeks to facilitate the immediate availability of QHIN services.

Require the QHIN Message Delivery modality in QTF using IHE Cross-Community Document Reliable Interchange (XCDR) profile with a future transition to FHIR

HIMSS recommended that The Sequoia Project move forward with “Option 1” on its question related to if QTF should include message delivery — requiring the QHIN Message Delivery modality in QTF using the IHE XCDR Profile with a future transition to FHIR. From the technical perspective, HIMSS believes it is important to use an open standard for message delivery and the IHE XCDR protocols are in line with what the community is using today. In addition, when positioning QTF for the future, all IHE protocols, including XCDR, co-exist with FHIR by design, i.e., support Representational State Transfer (RESTful) architecture.

Overall, HIMSS cited several factors that compelled the inclusion of message delivery. If the TEFCA Network is truly going to serve as a means to facilitate nationwide interoperability, HIMSS believed that the network needs to embrace multiple exchange modalities beyond “query” in order to appeal to all current and future health system participants. In addition, new 2022 requirements from CMS on the 2022 Inpatient Prospective Payment System (IPPS) Regulation for eligible hospitals and critical access hospitals to report a “Yes” on four of the existing Public Health and Clinical Data Exchange Objective Measures of the Medicare Promoting Interoperability also support incorporating message delivery into QTF.

Set robust expectations for patient matching algorithms across QHINs

HIMSS recognizes the importance of matching algorithms and the autonomy granted in QTF for QHINs to choose their own internal processes. The requirement prescribed by QTF should be focused on each QHIN being able to correctly identify the patient and serve as a differentiator based on the different methods that they deploy for matching as well as what they require of their participants. A high-quality patient matching process is necessary to preserve patient safety and establish trust across the TEFCA Network. HIMSS asked The Sequoia Project to look closely at this issue and set clear and robust expectations for QHINs as well as require periodic and regular reporting on the quality of patient matching rate performance.

Provide more details on the responsibilities for TEFCA participants and subparticipants

HIMSS expects more details on what is required of participants and subparticipants in the Common Agreement and accompanying Standard Operating Procedures, but there is information included in the QTF Performance Measures that are helpful steps to build on moving forward. Of particular interest are service level agreement requirements and parameters that The Sequoia Project is adopting in its RCE role for QHIN-to-QHIN exchange. HIMSS anticipates that some of these requirements will flow down from QHINs to participants and subparticipants, but more specifics about what is required would be helpful.

Glidepath to incorporate FHIR should focus on driving specific use cases

HIMSS recommended The Sequoia Project move forward with plans to incorporate FHIR into future iterations of QTF. The FHIR Roadmap under development as part of the process to finalize the Draft QTF should focus on driving specific use cases that utilize FHIR Documents, rather than a “date certain” when FHIR should be incorporated in QTF. Overall, future versions of QTF should point to the broader use of the FHIR Standard and HIMSS recommends a “fast follow” approach by building QTF on IHE infrastructure that allows for incorporating FHIR when those standards are performing at scale and can be appropriately integrated.

Full implementation of the ONC and CMS Interoperability Regulations provides another opportunity to embrace FHIR and parlay organizational regulatory obligations into demonstrating a commitment to the future use of FHIR in QTF and across the TEFCA Network. As ONC and CMS have prioritized the use of FHIR to better serve the needs of patients, HIMSS believes that the FHIR Roadmap’s implementation expectations should coincide with the requirements placed on the community to adopt these regulations.

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