The Centers for Medicare & Medicaid Services (CMS) issued the Inpatient Prospective Payment Systems (IPPS) and Long-Term Care Hospital Prospective Payment System (LTCH PPS) Final Rule on August 1, ensuring that participation in the Trusted Exchange Framework and Common Agreement (TEFCA) will qualify as part of the reimbursement scoring mix for hospitals and critical access hospitals in 2023.

This is great news for Health Gorilla and other potential candidate Qualified Health Information Networks (QHINs), including Carequality, eHealth Exchange, CommonWell Health Alliance, Epic, and others. With interoperability requirements continually evolving, being able to participate in TEFCA will make compliance for CMS incentive programs much simpler. Anticipated final rules are also expected to incentivize TEFCA participation as a part of provider payment reimbursement models.

“The fact that the federal government is using this carrot to encourage TEFCA participation is quite notable. CMS is throwing their weight behind TEFCA by incentivizing it — even before it exists,” said Steven Lane, MD, MPH, who was recently named Health Gorilla’s Chief Medical Officer. “One of the key questions with TEFCA has been ‘if you build it, will they come?’”

Changes to the Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals include making exchanges under TEFCA an option to satisfy the Health Information Exchange (HIE) Objective, beginning with the 2023 electronic health records (EHR) reporting period.

“People talk about government dragging their heels and moving slowly, and this is defying expectations in a really interesting way,” Dr. Lane said. “I think it speaks to how enthusiastic HHS is about making this happen, that they’re aligning things preemptively.” 

The IPPS and LTCH PPS rule, which will go into effect October 1, also includes changes to other interoperability measures such as the Electronic Prescribing Objective's Query of Prescription Drug Monitoring Program, which will be expanded and made mandatory.

Other notable shifts include the largest payment bump in 25 years, a "birthing-friendly" hospital designation to promote the quality and safety of maternity care, and the adoption of 10 new measures for the Hospital Inpatient Quality Reporting (IQR) Program, including three health equity-focused measures. A fact sheet outlining the IPPS and LTCH PPS Final Rule can be found here.

Health Gorilla and TEFCA

Health Gorilla announced our intention to become one of the first designated QHINs under TEFCA last year. As a QHIN, Health Gorilla will be able to expand on the interoperability solutions we already have in place, securely exchange data with other QHINs, connect our existing and future participants to a robust healthcare data network, and partner with Health Information Networks (HINs) that want to connect to and exchange data through other QHINs. 

For the past five years, Health Gorilla has evolved our product offerings to be consistent with the changing federal regulations for health IT. We have built a robust and secure health data and information exchange platform and we are one of the only organizations with memberships and connections to the CommonWell Health Alliance and eHealth Exchange networks, and the Carequality framework, which continues to benefit individuals, healthcare providers, the rapidly growing digital health community, and other networks.

We built our FHIR-native Health Interoperability Platform with an eye towards TEFCA, preparing to satisfy the ONC's stated goal of establishing a nationwide floor of universal interoperability. Our library of APIs and software products power foundational healthcare workflows and data exchange scenarios and enable an easy on-ramp to the national exchange of data. As one of the few known commercial entities applying for the QHIN designation, Health Gorilla plans to act as a liaison between the healthcare market and TEFCA governing bodies. We believe that pairing our close relationship to the market with services that achieve the national interoperability and exchange goals of the 21st Century Cures Act will allow us to develop more efficient data flows, expand our services, and create more innovative lines of business, all while reducing the intricacies and burden of exchange.

ONC and The Sequoia Project, TEFCA’s Recognized Coordinating Entity, announced the publication of TEFCA in January 2022. The application period for QHINs is expected to open in the fourth quarter of 2022.

Learn more about Health Gorilla’s Path to QHIN here.