Trusted Exchange Framework and the Common Agreement | Baker Ober Health Act


Data sharing and interoperability have been key goals for healthcare providers, health plans, and other industry participants for several years, and the office of the National Information Technology Coordinator on Health (ONC) of the United States Department of Health and Human Services (HHS) is poised to advance these initiatives in 2022. After years of discussion and development, on January 18, 2022, ONC and its entity of Recognized Coordination (RCE), The Sequoia Project, announced the release of the Trusted Exchange Framework and Common Agreement (TEFCA).

TEFCA is an important step towards establishing more ubiquitous access to health data, and because it is a voluntary framework, early entrants can realize certain competitive advantages. As expressed by Mariann Yeager, CEO of the Sequoia Project, and Micky Tripathi, National Health Information Technology Coordinator, the publication and implementation of TEFCA should mark “the beginning of a new era of electronic exchange of health information in the United States »


“Electronic health data sharing has historically occurred in regional silos. Although Health Information Technology for Economic and Clinical Health (HITECH Act) and the 21st Century Cures Act have encouraged rapid expansion of the use of electronic health records and electronic health information exchanges (HIEs), the current environment has developed with certain limitations. In particular, because most HIEs operate in one state or region specific, geographic limitations tend to result in different or incomplete records for the same patient across multiple exchanges.Americans continue to move around the country.

To address these limitations, the 21st Century Cures Act directed the ONC to “develop or support a framework for the exchange of trust, including common agreement among health information networks nationwide “. TEFCA aims to facilitate the sharing of health information with the following goals in mind:

  • Goal 1: Establish a universal policy and technical floor for nationwide interoperability.
  • Goal 2: Simplify connectivity for organizations to securely exchange information to improve patient care, improve people’s well-being, and drive healthcare value.
  • Objective 3: Enable individuals to collect their health care information.

What is TEFCA?

TEFCA consists of two components: the Trust Exchange Framework and the Common Agreement. The Trusted Exchange Framework is a set of non-binding principles regarding standardization; openness and transparency, cooperation and non-discrimination; privacy, security and safety; access; equity; and public health. The framework aims to encourage the exchange of data between health information networks.

In addition, the Common Agreement is a form of agreement developed pursuant to Section 4003 of the 21st Century Cures Act to be entered by Project Sequoia as an NCE and each qualified Health Information Network ( QHIN). The agreement establishes key infrastructure and governance requirements that will help users across different networks exchange clinical information. It is expected that each QHIN will then execute consistent policies within their individual networks.

What is a QHIN?

A qualified health information network is, like an HIE, a network of organizations working together to share data. However, the structure is intended to operate nationally and to encourage national interoperability.

Each network will include:

  1. QHIN, which provides connectivity brokerage services;
  2. participants, which may include health information networks, EHR providers and others; and
  3. end users, such as health care providers, who use a participant’s services to send or receive health data.

A QHIN can interact and exchange information with other QHINs, under the supervision of the RCE.

Each network will be subject to the QHIN Technical Framework (QTF), which establishes the eligibility criteria to serve as a QHIN and spells out the functional and technical specifications that QHINs must meet in order to support connection to the exchange. ONC also continues to work with Project Sequoia to form a TEFCA HL7 Rapid Healthcare Interoperability Resource Roadmap to establish how the HL7 FHIR interoperability standard will be implemented across all healthcare record systems. ONC certified electronic health.

Next steps for industry participants

Health information networks will soon be able to request QHIN status, and health care providers, health plans, and other industry participants should be prepared for the proliferation of QHINs and improved interoperability and data sharing. The national application of a unified health information network has the potential to improve patient care, simplify medical records for providers, and increase patient access to a more complete view of their health information.

However, improved interoperability will also present new challenges, including the need to develop processes to align with updated QHIN participation requirements and to improve privacy and security practices based on availability. much more information. Organizations must also be prepared to facilitate broader access for individuals in accordance with current information blocking regulations.

Project Sequoia has scheduled a series of public webinars regarding TEFCA benefits, the application and review process, QHIN eligibility and onboarding, and a monthly information call, the next of which will be on February 15, 2022 at 12 p.m. AND.


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