On Monday, Health Gorilla’s Chief Customer Officer Dave Cassel and Chief Medical Officer Steven Lane led a webinar to discuss Health Gorilla’s QHIN™ designation and its benefits for healthcare organizations.
Here are the highlights:
What is the practical value of QHINs?
- Access more data
Organizations that traditionally have not participated in data exchange due to perceived security or privacy risks are now more likely to make the leap with the Trusted Exchange Framework and Common Agreement℠ (TEFCA) due to stringent security standards and government oversight, filling gaps in the patient’s record and reducing the burden on providers to manually search for and collect their patients’ data.
- Unlock exchange purposes
Gain a strategic and competitive advantage in your market by being the first to enable your customers to leverage this secure nationwide network to access data for a diverse array of use-cases.
- Capture future government incentives
TEFCA participation is not required today, but now that TEFCA is live, multiple government agencies have indicated that they are likely planning to increasingly incentivize participation. Organizations that participate in TEFCA now will be prepared for a rapidly changing regulatory landscape that could quickly affect your organization's bottom line and compliance.
What kind of incentives are being proposed?
- MIPS-eligible organizations can increase scoring for the Promoting Interoperability (PI) category through TEFCA (read more)
- The new HTI-1 final rule established a “TEFCA Manner” Exception which applies if the actor and requestor are both part of TEFCA (read more)
- CMS is developing reimbursement incentives to encourage and may eventually require TEFCA exchange (read more)
Unique value of Health Gorilla’s QHIN
- Health Gorilla is the only organization that has achieved designation as a QHIN under TEFCA and as a QHIO under California’s Data Exchange Framework.
- A single connection to Health Gorilla delivers national connectivity through the new TEFCA framework and broadened reach in California.
- QHIN participants have the option to leverage our platform to collate, organize, de-duplicate, and normalize data to FHIR standards into a single record, supporting API integrations and saving time for care teams.
- In addition to QHIN, Health Gorilla has value-add data solutions not available within TEFCA and California’s Data Exchange Framework, such as national ADT alerts, SDoH data, and lab ordering solutions.
Watch the recording
Click here to access the recording.
Questions asked by the audience
Question: If we are a part of QHIN, do we need to be part of QHIO?
Answer: If you operate in California, you likely need to comply with the Data Exchange Framework (DxF). A QHIO will make it much easier for you to do this. QHINs can help with DxF compliance, but QHIN services alone may not address all aspects of the DxF today.
Question: Will QHIN queries be requested and received directly from my EHR?
Answer: All TEFCA participants will access the new framework through a QHIN. Some EHR vendors may choose to establish a relationship with a specific QHIN, or even be a QHIN themselves, while others may be agnostic to the QHIN their customers choose. Queries submitted through any QHIN are able to be transmitted to all QHINs to access data from all connected participants and sub-participants, including providers participating in TEFCA through their EHR.
Question: Does QHIN or QHIO status have any bearing on point to point integration of interoperability?
Answer: While point-to-point interfaces and connectivity will have their place for years to come, the exchange offered through TEFCA, especially as we follow the FHIR Roadmap for TEFCA Exchange beginning next year, should provide another faster, cheaper option to address an increasing number of use cases.
Question: If data is normalized and consolidated, do you provide visibility into the source record?
Answer: Absolutely. We will work with you to provide you with the data you would like. If you would rather have a federated model and bypass our functionality entirely, that is fine too. We have a flexible toolkit that provides a range of options to access our platform and data.
Question: Can a patient mobile app leverage TEFCA so patients can maintain all of their medical records at one place?
Answer: Yes, a patient exercising their individual right of access to health records is one of the supported use cases for TEFCA. It's early days for this use case but there are promising signs of progress, with successful transactions for individual access being completed in the first 24 hours of live TEFCA exchange.
Question: Is there an alternative for individuals that don't want to register their facial image or other biometric with CLEAR for id proofing to access their data?
Answer: TEFCA does support individual access services using what’s called IAL2 authentication standards for access to your own data. The IAL2 standard does involve biometrics and comparing them to a government issued ID; that's how it verifies that you are who you say you are. That is not the only way to service individual access requests. The other way is to use your credentials for a portal that your provider offers, called OAuth2. This is also being contemplated for inclusion in the TEFCA in 2024. But, IAL2 is here today and it is working well for the majority of people.
Question: What control do you provide individuals whose data is being transferred? If I do not want my pregnancy status disclosed to an entity who queries for it specifically or as part of my general health record, how can I prevent access to this?
Answer: Emerging regulations and their ramifications for patients require us to approach this very seriously. Today, the best approach for any person to protect their data from being shared is to tell that provider not to share it, and HIPAA gives every individual the right to request restrictions. In parallel, we are also working with others across the health IT industry to develop tools to technologically restrict certain data from being shared. But today, the best approach is to make a request to your provider.
Question: Regarding Individual Access, what information do you expect to be available to individuals at the beginning? Can I use Individual Access now if I register with one of the two companies you mentioned?
Answer: TEFCA deployment just started last week. The responses we’ve seen for Individual Access so far tend to be from health information exchanges, and if you’re in one of these HIEs’ regions, you’re likely to get a reasonable representation of your medical record. There are some caveats, but we do expect IAS to have success in certain regions and we expect it will grow over time.
Question: Will TEFCA help AI/ML companies to get access to patient-level health information to build personalized risk scores for certain health issues?
Answer: Potentially yes, as long as the request for data matches with one of the supported exchange purposes. Right now, we’re primarily looking at Treatment and Individual Access, and over time, additional use-cases will open up. Today, to get sufficient data, there is a need to align with a treatment use case, but over time, organizations could receive sufficient data from additional exchange purposes. Organizations looking to identify care gaps with AI or ML should reach out to us to discuss their specific use cases.
Question: We still see 70%+ of our document exchange happening via fax. What does QHIN do to fax traffic? We see the prevalence of fax based on the fact it's the easiest way for 2 systems to 'talk' to each other. Sounds like QHIN is another piece of 'plumbing' I need to connect to - whereas fax is just so easy.
Answer: TEFCA does support push messaging which many hope will eventually be as easy as fax as more and more participants go live. Today Direct messaging, also available through Health Gorilla, can be used in lieu of fax in many circumstances. Fax, of course, is not optimized to exchange discrete data or to integrate that data into workflows at the receiving organization. Many hope to eventually “axe the fax” in healthcare. Hopefully TEFCA push messaging will provide an accelerant in this direction.
Question: As a Payer, how can I prepare to start sending data to a QHIN? Can you give me details on the technical readiness? Also, how can payers be technically ready to access data in bulk and at per member level.
Answer: We typically involve a solution architect to understand your use-case at a deeper level, ie your file formats, technical transactions you envision using with us, etc. To my earlier point on the flexibility of our platform, we can discuss the best ways for you to interact with our platform, whether that's in bulk or individual queries. We envision bulk FHIR being part of the QHIN technical arsenal soon, but today, we would work together to make it work to serially send transactions for patients that would be provided in bulk.
Question: Would members/patients have to consent to share before consumers can pull data from a QHIN?
Answer: Consumer access to their own health records does not require consent, as the fundamental premise is that the request is being made by the consumer him or herself, or by someone legally authorized to act on the consumer’s behalf. More generally, consent is not required for most QHIN-facilitated information exchange, which aligns from a regulatory standpoint with HIPAA at the federal level.
Question: If my EHR vendor is going to act on my behalf in joining your QHIN, what are their steps as opposed to my steps in the implementation process?
Answer: A number of EHR vendors are or are planning to become QHINs with the intent of serving their existing customer base. It probably doesn’t make sense for most EHRs to become QHINs, so if you’re a provider using an EHR, it's worth talking to them and asking what is their plan for TEFCA. A few QHINs are ready to onboard EHRs into TEFCA, Health Gorilla being one of them. We have a number of EHRs currently onboarding with Health Gorilla. The implementation steps taken by the EHR, and what may remain for you to handle on your own, will vary from EHR to EHR, and you will need to consult your EHR vendor for their specific approach.
