A Guide to TEFCA's Six Exchange Purposes

The 21st Century Cures Act, signed into law on December 13, 2016, by the Obama administration, was designed to help accelerate medical product development and bring healthcare innovations to patients who need them more efficiently. The Cures Act also advocates for the delivery of greater interoperability, promotes the adoption of electronic health records (EHRs), and supports human services programs.

The Cures Act called on the Office of the National Coordinator for Health Information Technology (ONC) to develop or support a Trusted Exchange Framework, including a Common Agreement, among health information networks nationally.

The Trusted Exchange Framework and Common Agreement, commonly referred to as TEFCA, was released on January 5, 2018, and defines a standard set of principles, terms, and conditions that enhance the Common Agreement. When operational, it will decrease the administrative burdens associated with electronic health information (EHI) and establish universal interoperability standards across the country between health information networks (HINs).

While the permitted purposes defined by TEFCA have changed slightly from version to version, the overarching theme has been to increase the number of data exchange purposes available to the healthcare community. Non-treatment purposes have traditionally received limited attention and low response rates by networks and consortiums, which has led to a significant gap in national interoperability. Including them in the TEFCA regulations will ensure that these types of requests are responded to and will begin closing the gap on nationwide interoperability.

TEFCA will also establish Qualified Health Information Networks (QHINs), the certified entities and connectivity brokers responsible for facilitating the national exchange of health information. For HINs to achieve a QHIN Designation, they will have to adhere to and support the governing approach outlined in the common agreement and show that they have the necessary infrastructure to support the QHIN technical and functional requirements outlined in the QHIN Technical Framework.

Below we define the new exchange purposes, discuss how Health Gorilla's services satisfy each of them and discuss our next steps as we pursue our QHIN designation.

What are the Expanded Exchange Purposes

The expanded exchange purposes outlined in the Common Agreement include treatment, individual access services, public health, benefits determination, HIPAA-defined payment, and health care operations. 

1. Treatment - Treatment is defined as the provision, coordination, or management of health care by one or more health care providers. It also includes the coordination or management of healthcare by a third-party provider, a consultation between providers treating a common patient, or the referral of a patient from one provider to another.
2. Public Health - The public health exchange purpose refers to any request, use, disclosure, or response authorized under HIPAA regulations or other applicable laws regulating public health activities.
3. Payment - Payment refers to the various activities that healthcare organizations use to obtain payment or a reimbursement fee correlated with healthcare services. It also encompasses health plans acquiring premiums to satisfy their coverage responsibilities. 
4. Benefits Determination - Benefits determination refers to federal or state government agencies deciding whether a person is eligible for federal or state benefits for any reason other than health care. 
5. Healthcare Operations - Healthcare operations refer to certain administrative, financial, legal, and quality improvement functions of a covered entity (CE) essential to running its business and supporting treatment and payment activities.‍
6. Individual Access Services - Individual Access Services outline the rules and regulations that allow patients to receive a copy of their electronic health records (EHI). They also ensure that patients have the ability to direct a copy of their records to another provider or entity authorized by the individual.

How Health Gorilla Satisfies The Expanded Exchange Purposes

Health Gorilla has been adhering to the known 21 Century Cures Act and TEFCA regulations for the last few years and has developed our Health Information Network, Healthcare Interoperability Platform (HIP), and robust data engine specifically to satisfy all six exchange purposes.

While our team offers a suite of interoperability solutions, it's two of our flagship products that satisfy the exchange purposes included in TEFCA. 

The first is Patient360, which is available as a web-based application or through our FHIR-based clinical APIs. Patient360 supports a diverse set of clinical use cases and satisfies the treatment, payment, health care operations, benefits determination, and public health exchange purposes by allowing the entire healthcare ecosystem to seamlessly access and exchange data.

Our other product, which addresses the individual access purpose, is Patient Access. Patient Access enables individuals to securely access their comprehensive health records using IAL-2 compliant methods and allows them to share their electronic health records (EHR) with providers or other trusted organizations via our mobile app or API-integrated product.

What’s Next for Health Gorilla

Health Gorilla will be applying to become one of the first designated Qualified Health Information Networks once the final version of TEFCA is released, which we expect to be during the first quarter of this year. 

As a designated QHIN, we will continue to offer our well-known interoperability solutions but also expand our services as we begin facilitating data exchanges for new purposes. This will allow us to provide our services to a larger pool of the healthcare community and increase how current and future clients can leverage our solutions. 

Overall the QHIN Designation will increase our ability to facilitate access to health data across the country and allow us to deliver additional efficiencies and value to our Participants and Subparticipants. By ensuring interoperability between the networks we represent and minimizing one-off connections, we will simplify data exchanges for our network.

Ready to Expand Your Access to Clinical Data?

If you are part of a healthcare organization and interested in expanding the data available to your physicians or patients, the Health Gorilla team is here to help. We offer a comprehensive implementation plan which includes a dedicated implementation specialist and solutions architect who will work with you to configure the connection between our suite of APIs and your application. We tailor our implementation to your organization's unique clinical data workflows and provide access to the Health Gorilla development sandbox. Our team of experts is available to answer any questions through the testing and validation period. If you have any additional questions or are interested in exploring a partnership with Health Gorilla, please contact us.

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References:

https://www.healthit.gov/sites/default/files/page/2019-04/TEFCADraft2UsersGuide.pdf

https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/disclosures-treatment-payment-health-care-operations/index.html

https://www.healthcareitnews.com/news/onc-says-tefca-will-be-live-2022

https://www.cdcfoundation.org/what-public-health