Qualified Networks emerge as the lynchpin for TEFCA

QHINs will be key carriers for interoperability, but questions remain about the selection process and timeline for designation.

The release of the final Trusted Exchange Framework and the Common Agreement to further nationwide data exchange, released January 18, is viewed as a large step forward in the implementation of full interoperability.

However, questions remain regarding which entities will be designated as qualified health information networks (QHINs) to perform data exchange, and how these determinations will be made.

QHINs will be the nervous system within the TEFCA ecosystem. They will directly connect to each other and enable their participants to engage in data sharing – they’ll route queries, responses and messages. Each QHIN will voluntarily sign the just-finalized common agreement with the Sequoia Project, the recognized coordinating entity that has responsibility for designating, onboarding and providing oversight of QHINs.

The application process will open in about 90 days to ensure that prospective QHINs have time to review the resources released and attend educational events that the Sequoia Project will be hosting, said Mariann Yeager, CEO of The Sequoia Project.


While more detailed QHIN criteria won’t be known until a new standard operating procedure is released by Sequoia, some of the requirements are included in a Qualified Technical Framework published January 18.

The Sequoia Project and the Office of the National Coordinator for Health Information Technology have indicated what they’re looking for. “We expect health information networks that support robust, high-volume exchange will likely apply to become QHINs. TEFCA will serve as a backbone for exchange, not unlike the power grid, and so we will seek QHINs that have robust security, functionality, operational history and other criteria,” Yeager said.

QHINs additionally will need to be “sophisticated” organizations capable of connecting existing providers and networks, said Micky Tripathi, National Coordinator for Health Information Technology.

The standard operation procedure is expected to be published in the coming weeks.

It does appear that existing local and state health information exchanges (HIEs) can participate in the QHINs without having to become one themselves. The exchange scenarios outlined in the Qualified Technical Framework expect that smaller health information networks, including HIEs or vendor and payer-based exchanges, can be part of the chain of participants, and thus can forward queries, messages and responses between a QHIN and an individual provider.

“We hope that today’s HIEs review TEFCA with an eye to how they fit in this new paradigm. There is a role for everyone, whether as a QHIN or [HIN] connecting through a QHIN,” said Yeager.

It’s still premature to speculate how many entities will become QHINs, and Yeager suggested a wide range of more than two QHINs but fewer than 100.  There will be an initial set of QHINs designated, but the application process will be “rolling,” she said, suggesting that more organizations can seek the designation over time.

Also unknown is how the requirements in the common agreement will “flow down” from the QHINs to their participants and sub-participants, said Lisa Bari, CEO of Civitas Networks for Health, which supports information exchange providers.

The timing of implementation also may shift. Onboarding the designated QHINs will depend on their preparedness, technical testing and partner testing. The earliest that implementation may occur is the fourth quarter of this year, Yeager predicted.

And it’s not yet known which organizations will apply to become QHINs, although several have already expressed interest. For example, eHealth Exchange believes it is well-positioned to be a QHIN because it was created to improve patient care via interoperability, says Jay Nakashima, its executive director.

“As a non-profit health technology provider governed by federal agency and private sector healthcare leaders, there’s no question we’ll focus on facilitating broad, trusted exchange, as economically as possible,” he said.

Other entities also believe they’re good QHIN candidates. “Health Gorilla has been working with ONC and (the Sequoia Project) for some time and believe we are perfectly positioned to bridge the gap between TEFCA’s interoperability goals and the private sector….Our library of APIs and software products power fundamental healthcare workflows and data exchange scenarios and enable an easy ‘on-ramp’ to the national exchange of data, said Steve Yaskin, CEO and co-founder of Health Gorilla.

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