Will TEFCA shove health information exchange forward?

After decades of inertia, there are finally signs of progress, as fed agencies push the pile. But questions surround whether hurdles will be overcome.


The recently announced final version of the Trusted Exchange Framework and Common Agreement could be one of the most consequential steps of the past decade to enable the easy exchange of healthcare information. Or not.

Some great minds have been digging deep into TEFCA’s potential impact. There are worries about the details, questions about regulatory overreach or duplication, and Groundhog Day inferences that we’ve seen this all happen before, albeit in slightly different trappings, with progress proving to be elusive.

TEFCA is complicated in structure and encumbered by a salad bar full of acronyms (because it’s healthcare, after all). As one person on Twitter noted, “Why does it have to be so complicated?”

There are three important TEFCA questions to consider: Why is it here? What is it trying to do? And what are its chances of success?

Why is TEFCA here?

The issue of information exchange has dogged the industry ever since healthcare organizations plugged in computers. It’s the evil twin of the weather; everybody complains about it, but no one can do anything about it.

When “meaningful use” provisions for earning electronic health record incentives were rolled out a dozen years ago, it was clear that the federal government saw information exchange as vital.

At the 2016 HIMSS Conference, then-HHS Secretary Sylvia Burwell outlined a plan for major healthcare provider organizations, payers and professional associations to commit to three objectives in information sharing. But, I wrote later that year that the effort ran aground when vendors and providers couldn’t agree on what interoperability meant.

Federal agencies, which were interested in calling greater attention to the need for easy information exchange, eventually renamed the meaningful use program “Promoting Interoperability.” And after many years of giving the industry every chance to solve the information exchange problem, regulators determined that not enough progress had been made. So now, agencies are trying to nudge, or more forcefully push, the industry to more easily exchange health information so that clinicians have access to all the data they need to make the right treatment decisions and save lives.

Key steps include the gradual implementation of FHIR-enabled APIs, enforcement of regulatory provisions that prohibit the blocking of information sharing and now TEFCA.

What is TEFCA trying to do?

I liken the TEFCA initiative to the strategy for building the national railroad system.

Back in the early days of railroading, there were no standards for vital components, including the gauges for rails. Without a standard width, there could be no easy exchange of rail cars. But after rail widths were standardized, cars could be easily shuffled from one railroad to another.

Ah, if only it was so simple in healthcare.

TEFCA aims to provide some standardization that enables common understanding among data exchange organizations. And the qualified healthcare information network process seems to be trying to standardize the “rail gauge” for how these entities interoperate.

Although TEFCA participation is now optional, participation likely eventually will become required for those who take part in certain federal programs. Interoperability rules, as part of the common agreement, are expected to flow down from the QHINs to the healthcare organizations that use them, and from there down to “subparticipants,” including clinicians’ offices, affiliated ambulatory care providers and others. The Sequoia Project will determine whether a health information exchange organization can be designated as a QHIN and serve as a key connective hub in a network of QHINs.

TEFCA designates HL7’s FHIR (Fast Healthcare Interoperability Standard) as the eventual go-to standard for information exchange. Setting an aggressive timetable, regulators are calling for significant implementation of FHIR, and the operationalizing of TEFCA, in 2023.

But achieving this timeline could prove challenging, given other important pending regulatory projects, including enforcing information sharing/blocking prohibitions, looking for input on electronic prior authorization approaches and standardizing terminologies.

What are TEFCA’s chances for success?

For the TEFCA rollout to succeed, several key questions need to be answered, including:

  • How can a potential shift from optional to required participation be managed and sequenced?
  • How easily will TEFCA-based exchange actually flow down to all participants – particularly smaller entities – in the healthcare chain?
  • How easily will HIT vendors meet TEFCA requirements and make changes within their products?
  • Can FHIR maturity, including the ability to handle transactions at scale, be achieved by next year?
  • Do FHIR and TEFRA adequately address privacy and security? And should HIPAA be modified to enhance data exchange safeguards?

Déjà vu fatalism

Perhaps the most vexing challenge is overcoming the sense that we’ve all been here before. Despite repeated efforts to ease information exchange, the healthcare sector has made little progress toward true interoperability.

John Moore of Chilmark Research said he had flashbacks to the Data Use and Reciprocal Support Agreement of 2009, better known as DURSA, that was intended to facilitate the creation of a national health information network.

What has changed since 2009? There’s more regulatory pressure to make information exchange happen. There’s more desire among consumers to control where they can direct medical records. And there’s more commitment from some within industry segments to achieving efficiency with information exchange, buttressed by better technology.

TEFCA may not be perfect, but we cannot afford to wait any longer to achieve meaningful information exchange that paves the way for better healthcare. After all, I wrote an HDM cover story way back in 1995 about a new model for exchange called Community Health Information Networks, or CHINs, that never really caught on. Some 27 years later, it’s time to get going.

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