ONC continues to re-draw the map of patient care with its Trusted Exchange Framework and Common Framework (TEFCA) Draft 2 that aims to:

• Provide a single “on-ramp” to nationwide electronic health connectivity;
• Ensure electronic information securely follows when/where needed; and
• Support nationwide scalability for network connectivity.

TEFCA Draft 2 is an alphabet soup of abbreviations.  Two of the most important concepts are the Qualified Health Information Network (QHIN) -- the hub and main actor in the TEFCA universe --  and the Recognized Coordinated Entity (RCE). The yet-to-be selected RCE  -- a non-profit, industry-based organization -- will deal with the Common Agreement that creates baseline technical and legal requirements for sharing electronic health information on a nationwide scale across disparate networks.

eHI recently submitted feedback to ONC on TEFCA Draft 2.  We congratulated ONC on:

• QTF - Adding a separate QHIN Technical Framework (QTF);
• More Reasonable Timelines - Extending the timeline for QHINs to update and comply with agreements and technical requirements from 12 to 18 months;
• Positive QHIN Refinements - Refining QHIN exchange modalities and pre-requisites, to better reflect today’s healthcare practice and market realities; and
• Flexibility and Phase-Ins - Incorporating more flexibility to build from existing exchange capability and standards, as well as a phasing-in of appropriate provisions and requirements.

eHI cautioned ONC on:

• Tread Carefully - eHealth Initiative cautions ONC to be very mindful the Congressional intent expressed in the 21^st Century Cures Act that the TEFCA avoid disruption and duplication of “existing exchanges between participants of health information networks.” And, where existing networks that meet needs are in place, ONC is encouraged to build upon them.
• Complex QHINs - ONC’s TEFCA Draft 2 document offers many additional details about the Qualified Health Information Networks (QHINs). eHealth Initiative expresses concern and caution about the complexity of the QHIN concept and its ecosystem. We urge ONC to pay close attention to public comments about whether the QHINs, as currently conceived, will work effectively and build enough value.
• Sustainability – The TEFCA processes, including the RCE and the QHIN, must be financially sustainable and not overly dependent on federal funding.
• RCE Independence – The RCE should have significant independence from ONC with transparent accountability (including to ONC) and governance that engages all stakeholders, and particularly end-users.
• Fees - eHealth Initiative requests additional information around QHIN to QHIN fee details, particularly what constitutes “reasonable and non-discriminatory criteria” that a QHIN is to use if it charges any fees to another QHIN. Effective ONC and RCE communication with relevant stakeholders on fee issues will be absolutely critical.
   

See our attached comments for more details. eHI is in a unique position to comment and offer insight on federal government as the only national organization that represents all stakeholders in the healthcare industry. Stay tuned for more!