In the world of health data exchange, the Trusted Exchange Framework and Common Agreement (TEFCA) represents a major step forward in setting a universal floor for interoperability. With this framework, the Office of the National Coordinator for Health IT (ONC) is creating the rules of the road that will allow providers, patients, and other stakeholders to securely access privacy-protected health information from a national network of sources in near real-time.
However, like any transformative initiative, TEFCA has faced its share of criticisms, some worthy of discussion but others entirely misguided. Given that TEFCA will ultimately govern how the vast majority of health data is exchanged, we felt it was necessary to correct the record with facts and evidence. With a government-sponsored initiative as wide reaching as this one, we need to separate fact from fiction, and address some of the misconceptions surrounding TEFCA.
Claim: ONC’s recent proposal for an Information Blocking exception for TEFCA participants aims to block patient access through TEFCA.
Fact: Quite the opposite, TEFCA clearly and unequivocally supports enabling individuals to access their own health information. It mandates all participants to respond to Individual Access Services (IAS) queries made under TEFCA, ensuring that patients have digital access to their health information. ONC did propose an information blocking exception for TEFCA participants that was not well received and might have inadvertently disincentivized TEFCA participation. This feedback was recognized in the public comments on the proposed rule, and ONC is unlikely to include the initially proposed exception in the final rule.
Claim: IHE-based document exchange, which will be supported by the initial TEFCA implementation, is outdated and underutilized.
Fact: Document exchange based on IHE protocols represents the vast majority of current health data exchange, with billions of transactions a year currently, largely supporting the Treatment purpose of use. It is the engine behind all of the success we’ve had in establishing national interoperability. The first version of TEFCA intentionally incorporated the current dominant transaction pattern so as to minimize industry disruption and to garner early voluntary adoption. IHE-based exchange was the right move to get providers and other participants in the healthcare ecosystem on board.
Claim: TEFCA doesn’t use FHIR and limits the potential of FHIR-based exchange.
Fact: The initial use of IHE-based document exchange for QHIN-to-QHIN exchange does not in any way restrict TEFCA participants from leveraging FHIR. Participants can utilize FHIR exchange with their QHIN or between participants using the same QHIN. Moreover, the Recognized Coordinating Entity (RCE) has a transparent plan to integrate FHIR-based exchange in the second version of the QTF and CA, with meetings being scheduled now and implementation expected by early 2024.
Claim: Data within C-CDA documents, which will be exchanged over TEFCA, is "non-computable.”
Fact: This claim is patently false. The fact is that the vast majority of discrete, computable, interoperable health data is exchanged today using C-CDA documents, which serve as flexible containers facilitating the transmission of many discrete and computable elements. We’re talking about billions of documents and hundreds of billions of data points every year, leveraged by providers, analyzed by administrators, and retrieved by patients. Providers, public health agencies, and others routinely extract computable data from C-CDA documents to populate EHRs and drive analytical insights to improve patient care.
TEFCA remains a pivotal initiative in the drive towards national health data interoperability, ensuring that patients have seamless access to their health information and that healthcare providers can make informed decisions based on comprehensive data. It is appropriate and desirable for the various agencies and offices within HHS to continue to look for opportunities to incentivize participation in TEFCA, which will initially be voluntary. As there are no current statutory requirements to exchange health information via TEFCA, it is imperative that we collectively identify opportunities to encourage use of the new framework, as it will only be through early engagement and successful use that we will see the broad adoption necessary to fulfill the promise of this broad reaching initiative.
In our healthcare system, we must take incremental steps that allow the existing system to transition smoothly to a better one, rather than imagining a new reality without a credible path to achieve it. Creating a single, federally-supported framework that modernizes our nation’s health data exchange infrastructure is a tremendous feat. There will always be enhancements to be made, and more work to be done, but this does not detract from the immediate value TEFCA can provide. TEFCA remains a beacon of hope in our journey towards a more interconnected, patient-centric, high value healthcare system. Let's focus on constructive dialogue that propels us all forward in this mission.
