TEFCA: What’s New?
Overview
Draft 2 of the Trusted Exchange Framework and Common Agreement (TEFCA) was released on April 19, 2019, and ONC has issued a deadline for comments on June 17, 2019. The input of eHI and other organizations on TEFCA Draft 1 was taken into consideration for this iteration. The new TEFCA process will be overseen by a private sector Recognized Coordinating Entity (RCE) to be selected by ONC and operated through a cooperative agreement. A major building block of TEFCA is the Qualified Health Information Network (QHIN).
ONC’s TEFCA Draft 2 documents and related materials can be found HERE.
Included in ONC’s TEFCA Draft 2 packet are the:
- Trusted Exchange Framework (TEF) Draft 2 (Appendix 1)— A common set of principles designed to facilitate trust between HINs and by which all HINs should abide in order to enable widespread data exchange;
- Minimum Required Terms and Conditions (MRTCs) Draft 2 (Appendix 2)— Mandatory terms and conditions that Qualified Health Information Networks (QHINs) voluntarily agree to follow; and
- QHIN Technical Framework (QTF) Draft 1 (Appendix 3) —Appendix 3) al Framework (QTF) Draft 1ualified Health Information Networks
TEFCA Draft 2: Policy and Technical Evolutions
Below are some key changes and additional details offered from TEFCA Draft 1 to Draft 2. ONC is looking to the public for input on the TEFCA Draft 2 and key recommendations throughout the document. eHI will be commenting.
QHIN Details and Designation Process
A QHIN, is an entity with the technical capabilities to connect Participants on a nationwide scale. A QHIN must meet the definition of a Health Information Network (HIN) and satisfy all of the conditions of the Common Agreement and accompanying QHIN Technical Framework (QTF). More details have been added to the QHIN definition and it QHINS have also been broadened to include more stakeholders. categorized as Participants, Participant Members and Individual Users. The process for applying and receiving an official QHIN designation from the RCE is now also outlined on page 13 of the TEFCA Draft 2 document. For the HIN to be eligible for QHIN designation consideration and selection process, they must at a base level:
- Operate an existing network that provides the ability to locate and transmit EHI between multiple persons or entities electronically and exchange EHI in a live clinical environment;
- Meet all the applicable federal and state laws; and
- Submit a plan to the RCE that includes how they will meet all the QHIN requirements.
QHIN Message Delivery (Push) Added
In TEF Draft 1, ONC required that all QHINs support three types of exchange modalities related to Electronic Health Information (EHI). They were Targeted Query (a QHIN’s electronic request for a patient’s EHI from another specific QHIN), Broadcast Query (a QHIN’s electronic request for a patient’s EHI from all other QHINs) and a Population-Level Data Exchange (a QHIN’s electronic data request for a population of one party’s participant). Letters from the public commented that while Population-Level Data Exchange is necessary for the overall development of TEFCA and is required by the 21st Century Cures Act, more time is needed before it is mandated. In addition, a key comment theme was support for a “push-based” exchange modality to be added into the second draft. ONC therefore added the QHIN Message Delivery in the Population-Level Data Exchange’s place. The Message Delivery modality will allow a QHIN to send EHI to a direct address at one or more QHINs. This type of modality is a “push-based” transaction and would play a significant role in the transitions of care.
Exchange Purposes Updated
The TEF Draft 1 included Treatment, Payment, Health Care Operations, Public Health, Individual Access (as those terms are defined by the HIPAA Privacy Rule), and Benefits Determination, as required Exchange Purposes Comments after the release of Draft 1 led many members of the public to be concerned that the push to implement so many exchange purposes right away would be too burdensome for the Health Information Networks (HINs). In order to reduce the burden, ONC is proposing that the Common Agreement will initially require exchange for only a subset of activities in Payment (Utilization Review) and Health Care Operations (Quality Assessment and Improvement, and Business Planning and Development) as defined in the HIPAA Privacy Rule. The requirements to exchange for purposes of Treatment, Public Health, and Benefits Determination will remain the same as proposed in TEF Draft 1.
QHIN Technical Framework Added
In TEF Draft 1, the QHIN Technical Framework (QTF) was to be included in the Common Agreement. But commenters emphasized that providing more information through an implementation guide rather than in the Common Agreement. would be helpful The QTF document has been included in the TEF Draft 2 release, and ONC wishes for comment regarding the addition.
Timelines Extended
Under TEF Draft 1, QHINs were given twelve months to conform to the requirements in the Common Agreement, but after comments challenging the short period of time, ONC extended the time period to eighteen months.
Fees
Under TEF Draft 2, ONC notes that QHINs are not legally allowed to charge another QHIN to exchange EHI for Individual Access Services. They also may not impose more fees once the other QHIN has the EHI.
Implications for eHI Members
Some key HHS goals in putting forth TEFCA and other evolving health care and interoperability initiatives are to:
- Improve the interoperability of electronic health information;
- Enhance care coordination; and
- Promote patient access to and control over their health information.
eHI and its Policy Steering Committee will be looking in the coming weeks --through our powerful, multi-stakeholder lens -- at how the TEFCA Draft 2 meets these objectives. For individual organizational comment on the TEFCA Draft 2 documents, go HERE and click to the bottom of the page.
