On Monday, June 17, HIMSS and PCHAlliance submitted a comment letter to the Office of the National Coordinator for Health IT (ONC) in response to the Trusted Exchange Framework and Common Agreement (TEFCA) Draft 2.
We appreciated ONC’s work to create TEFCA and provide a single on-ramp to nationwide connectivity and voiced support for the overall concept behind TEFCA. However, HIMSS and PCHAlliance expressed concern for the proposed structure and the impact that it could have on existing exchange processes. We asked ONC to create a nationwide exchange environment where the work of current interoperability efforts are fully leveraged to achieve the goal of a single on-ramp to connectivity across the country.
Highlights from the HIMSS and PCHAlliance letter include:
- Relax Requirements Around Provisional Qualified Health Information Network (QHIN) Status and Provide a Longer Glidepath to Full Adherence to the Common Agreement (CA)
We recommended that ONC not disrupt the existing successful business models of state and regional HIEs and HINs as well as other exchange entities, but builds upon their innovations, partnerships and successes thus far. In addition, we asked that Provisional QHINs as well as their Participants and Participant Members have the ability to maintain their provisional status for a significant period of time, but during that timeframe, they would gradually incorporate additional, more ambitious capabilities, exchange modalities and exchange purposes, that could be met by adapting the existing ecosystem of HIEs and HINs.
- Expand the Exchange Modalities to Include Push Transactions
HIMSS and PCHAlliance supported the three exchange modalities included in TEFCA Draft 2: QHIN Targeted Query; QHIN Broadcast Query; and, QHIN Message Delivery. The combination of “pull” and “push” transactions provides a cohesive backbone for nationwide exchange capabilities and allows different modalities to be used in the situations where they are best suited.
- Streamline the Exchange Purposes in the Initial Roll-Out, But Ensure TEFCA is Positioned to Expand Activities
We supported the initial focus of Exchange Purposes on Treatment, but asked that ONC work toward including the full Payment and Health Care Operations Exchange Purposes as well to ensure that as our health system evolves, we can continue to support the push toward value-based care delivery.
- Ensure a Robust Role for Connected Care Use Cases in the Future Framework
HIMSS and PCHAlliance asked ONC to recognize and prioritize the multiple connected care touchpoint opportunities in the framework, and provide clear inclusion and a path forward for connected care, specifically, an individual’s ability to contribute device data to TEFCA exchange processes.
- Align Privacy and Security Obligations Across the Healthcare Landscape
We want to ensure that there is alignment between TEFCA and HIPAA privacy and security obligations. Such alignment will minimize the impact on Covered Entities and Business Associates and increase the probability that they will move toward adopting TEFCA.
- Push for the Creation of a Patient-Focused and Driven QHIN
HIMSS and PCHAlliance asked for the creation of at least one QHIN where an individual could request a roll-up of all their EHI without the intervention of a clinician or provider organization.
- Clarify the Role of QHINs in Future Uses of Patient Data
We ask TEFCA to clarify that QHINs cannot use or sell the data that they are facilitating the exchange of without the consent of the entities that brought the information into the broader network.
In its TEFCA Draft 1 Public Comment Letter from February 2018, HIMSS also raised concerns about the impact that TEFCA would have on the current efforts underway across existing interoperability exchanges, networks and approaches. We endeavored to find a path forward that allowed existing interoperability entities to largely continue to function under their business models, qualify as QHINs, and have them report to the Recognized Coordinating Entity as the primary oversight mechanism of TEFCA.
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