The Structural Changes in the Second Draft of TEFCA
The Office of the National Coordinator for Health Information Technology (ONC), released the second draft of the Trusted Exchange Framework and Common Agreement (TEFCA) for comments, in April 2019. This draft contains important updates to the fundamental structure of TEFCA and the terms and conditions that govern the roles and responsibilities of Qualified Health Information Networks (QHIN).
The new draft contains three main sections which are as follows:-
The Trusted Exchange Framework (TEF): This section is made of six ‘Principles for Trusted Exchange’ which are designed to facilitate trust between participating QHINs. These principles also reduce variations in technical and federal policies that restrict the flow of Electronic Health Information (EHI), a basic requirement in the ONC’s aim to ramp up the efficiency of Patient Engagement and the Interoperability of healthcare systems. The six core principles are:
- Standardization:- Ensures the adherence of QHINs to federal policies, clinical best practices, and procedures.
- Transparency:- Specifies the uses and disclosures for QHINs to exchange health information.
- Cooperation and Non-Discrimination: To facilitate collaboration and cooperation between stakeholders across the continuum of care.
- Privacy, Security and Patient Safety: Ensures the integrity of patient health information and adherence to federal privacy policies.
- Access to EHI: Safeguards the ability of individuals (caregivers and patients) to easily access EHI and receive accountability from designated third parties on how this information has been used.
- Population-Level Data: Enables HIE participants to work with multiple patient records and to process population-level requests.
QHIN Technical Framework (QTF): The MRTC section comprises of functional and technical requirements that a HIN needs to fulfill to qualify as a QHIN, per the TEF. It lays down the foundation for the exchange of healthcare information between two QHINs. QTF establishes the technical and functional requirements that QHINs are required to conform to, for interoperability. It dictates the standards that QHINs must implement to achieve a seamless exchange of healthcare information. The QTF section goes on to propose the technology to facilitate the exchange of healthcare information including digital certificate policies, information encryption, user authentication, directory services, and information privacy preferences.
Minimum Required Terms and Conditions (MRTC): The MRTC section improvises on the terms and conditions that were previously included in the ‘Common Agreement’ section of the first draft of TEFCA. This section defines governing terms and charts out a course of action for QHINs for all the transactions they would engage in, once the framework would be implemented. The rules included in the MRTC section of the second TEFCA draft define, data quality, basic operations, transparency, health information privacy, security and all other vital obligations for QHINs to adhere to.
Key Changes in TEFCA 2.0
Updated Exchange Purposes: Adoption of a specific subset of ‘purposes’, payment and healthcare operations to align the framework better with HIPAA regulations.
Addition of QHIN ‘Push’ Message Delivery: Inclusion of the message delivery or ‘push’ modality and the removal of population-level data exchange.
Inclusion of the QHIN technical Framework: Separation of the technical standards into a specific framework, now called, QTF to enable independent development of technology, uninterrupted by the original policies included in TEF.
Broadening of QHIN definition: Allows for a broader set of HINs to qualify as QHINs.
Extension of Timelines: Entities that conform to TEFCA now have 18 months to implement updates in the Common Agreement instead of the 12 months specified in the first draft.
In Conclusion
The second draft of TEFCA is in perfect sync with the primary goal of the 21st-century cures act, which is to achieve nationwide interoperability. To achieve this goal, HINs need to agree on a common and minimum set of pre-requisites or guidelines to establish trust among each other. The second draft of TEFCA delivers these guidelines which would greatly improve the efficiency of EHI flow. This heightened efficiency of health information exchange provides caregivers with access to critical health care information at the right time. It also gives patients a more active role in their healthcare process. With care providers and patients being empowered to use EHI to vastly improve the quality of care delivered, episodes of misdiagnosis, increase in the cost of care due to inaccuracy on healthcare information and clinical process redundancies such as re-initiating diagnosis can be significantly reduced.
Puneeth Salian
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