Health Gorilla recently announced our intention to become one of the first Qualified Health Information Networks (QHIN) under the Trusted Exchange Framework and Common Agreement (TEFCA). We have been abiding by the 21st Century Cures Act and TEFCA standards since they were released in 2016. Still, we realize that the legislation and technology vernacular attached to this designation can be overwhelming and convoluted.
To make this information more widely available and understandable, we have created a list of frequently asked questions to help the healthcare community understand and navigate the changes coming in the first quarter of 2022. If there are any terms that you are familiar with and are not currently represented in the list, please reach out to Ryan Kelly to have them added.
The 21st Century Cures Act (Cures Act) was signed into law on December 13, 2016 by the Obama administration and is designed to help accelerate medical product development and bring new innovations and advances to patients who need them faster and more efficiently. The Act advocates for the delivery for greater interoperability, promotes the adoption of electronic health records (EHRs) and supports human services programs.
The Trusted Exchange Framework and Common Agreement (TEFCA) outlines a common set of principles, terms, and conditions to support the development of the Common Agreement, which was created to enable the nationwide exchange of electronic health information (EHI) between health information networks(HINs) to establish universal interoperability standards across the country between health information networks (HINs).
TEFCA will make sure that health information networks, health care providers, health plans, individuals, and other healthcare stakeholders have defined privacy and security requirements to protect patient data and ensure that secure access to their electronic health information is available when and where it is needed. TEFCA will also establish Qualified Health Information Networks (QHINs) as a mechanism to help facilitate a standardized method for national HIE interoperability, along with a new administrative organization, the Recognized Coordinating Entity (RCE), which The Sequoia Project was awarded in August of 2019.
The overall goal for the Trusted Exchange Framework and Common Agreement (TEFCA) is to establish a floor of universal interoperability across the country. The Common Agreement will establish the infrastructure model and the governing approach for the Trusted Exchange Network, for users in different networks to securely share basic clinical information with each other.
TEFCA will create a single on-ramp for Health Information Networks to send healthcare information, national scalability, and ensure that electronic health information will follow an individual when they need it. TEFCA will also improve the healthcare industry’s administrative burdens and improve organizational security by closing privacy gaps across networks and addressing vulnerabilities across HIPAA compliance, cyber protection and ransomware prevention.
The Common Agreement outlines the governing approach necessary to scale a national system of interconnected QHINs. It will act as a legal agreement that the RCE and QHINs will sign. Some provisions of the Common Agreement will flow down to other entities, including QHIN Subparticipants and participants.
The QHIN Technical Framework (QTF) describes the technical and functional requirements for interoperability among QHINs, including specification of the standards that QHINs must implement to enable QHIN-to-QHIN exchange of health information. The technical specifications discuss privacy and security steps, approaches for identifying and authenticating exchange participants, how to conduct patient discovery and identity verification, and the support required for exchange protocols.
The Sequoia Project, a non-profit 501(c)(3) was awarded cooperative agreement by the ONC as the Recognized Coordinating Entity (RCE) for TEFCA in August 2019. The Recognized Coordinating Entity (RCE) is responsible for developing, implementing, and maintaining the Common Agreement component of the Trusted Exchange Framework and Common Agreement (TEFCA). The Sequoia Project has two distinct subsidiaries, one for eHealth Exchange and one for Carequality.
QHINs are the certified entities responsible for facilitating the national exchange of health information and will act as connectivity brokers to ensure interoperability between the networks they represent. TEFCA defined the technical and legal requirements, or rules of the road, for nationwide electronic health information exchanges. The architecture will follow a “network of networks” structure, where QHINs serve as the super nodes and are responsible for connecting to other QHINs to facilitate the national exchange of data between QHINs, Participants, and Subparticipants. Each QHIN is responsible for the onboarding and management of their Participants and Subparticipants. Each QHIN will have to be certified by the Sequoia Project, which is the recognized coordinating entity (RCE), and by proxy, receive a government certification.
Health Gorilla becoming a QHIN would put us at the level of leading organizations in the market, a few being eHealth Exchange, Carequality, and Commonwell, and allow us to have additional influence on policy and the ability to drive decisions around broader exchanges of data. Health Gorilla as a QHIN would connect our existing participants and expand our market to onboard other participants and Health Information Networks that are required to connect to a QHIN. Additionally, all QHINs are required to exchange data, which further expands the opportunity to have a broader scope of data available.
Becoming a QHIN means Health Gorilla will be awarded a government status and connect to organizations outside of our network. This will expand our ability to enable or facilitate access to health data across the country and help create efficiencies that will deliver greater value to their Participants and Subparticipants and ensure interoperability between the networks we represent. We will also minimize one-off connections, which should reduce the complexity of data exchanges for our network.
The six exchange purposes in the Common Agreement, released in September 2021, include Treatment, Payment, Health Care Operations, Public Health, Benefits Determination, and Individual Access Services.
Yes, Health Gorilla’s platform and robust data engine make us uniquely positioned to fulfill all six permitted exchange purposes. The Treatment, Payment, Healthcare Operations, and Public Health exchange purposes are achieved through Health Gorilla’s platform and FHIR-based APIs, which facilitate national bi-directional exchanges of health information for permitted purposes and include integrations with major EMR systems and diagnostic vendors. Health Gorilla’s platform addresses the need for individual access through identity proofing and connects individuals with access to their information. Finally, Health Gorilla’s recent entrance into the life insurance market addresses the process of Benefits Determination, securely providing life insurance underwriters, re-insurers, and risk assessors with HIPAA-compliant, permission-based access to structured and complete medical records.