AHIMA Submits Comments on TEFCA Draft 2

AHIMA Submits Comments on TEFCA Draft 2

This web-exclusive Journal column highlights public policy initiatives at the federal- and state-level that impact the HIM profession, including news on AHIMA’s national and affiliated state advocacy initiatives, Congressional updates, news from federal regulatory agencies, public policy updates from state legislatures, and AHIMA’s public policy initiatives with other organizations.

By Lesley Kadlec, MA, RHIA, CHDA,


On June 17, 2019, AHIMA submitted comments and provided recommendations on Draft 2 of the Trusted Exchange Framework and Common Agreement (TEFCA).

Required under the 21st Century Cures Act, the TEFCA outlines a common set of principles, terms, and conditions to support the development of a voluntary Common Agreement that would enable nationwide exchange of electronic health information (EHI) across disparate health information networks (HINs). The TEFCA seeks to scale EHI exchange nationwide and ensure that HINs, providers, plans, individuals, and other stakeholders have secure access to their EHI when and where it is needed.

The TEFCA and the Common Agreement follow a “network of networks” structure, which allows for multiple points of entry and is inclusive of many different healthcare stakeholders, including HINs, health information exchanges, individuals, providers, public health agencies, payers, and health IT developers. Stakeholders will have an option of fulfilling the responsibilities for and participating as a Qualified Health Information Network (QHIN), a Participant, a Participant Member, or an Individual User. See the sidebar below for an explanation of each of these terms.

QHIN: An entity with technical capabilities to connect Participants on a nationwide scale. A QHIN must meet the definition of a HIN and satisfy all of the conditions of the Common Agreement and accompanying QHIN Technical Framework.

Participant: Participants may include persons or entities that have entered into a contract to participate in a QHIN. Examples include but are not limited to a health system, health IT developer, payer, or federal agency.

Participant Member: Participant Members may include persons or entities that use the services of a Participant to send and receive EHI. For example, if a QHIN is composed of health information exchanges, the health information exchange would be the Participant and those that use the health information exchange’s services (such as health systems, ambulatory providers, health IT developers, payers, and others) are the Participant Members.

Individual User: An Individual User represents an actual person who is the subject of the EHI, such as a patient, health plan member, or patient representative. Individual Users may have a direct relationship with a QHIN, Participant, or Participant Members depending on the structure of the QHIN to which they belong, but they are not themselves considered Participants or Participant Members.

Draft 2 of the Trusted Exchange Framework and Common Agreement consists of three main components:

  • The Trusted Exchange Framework (TEF) Draft 2: A common set of principles designed to facilitate trust between HINs and by which all HINs should abide to enable widespread data exchange. The principles in the TEF are foundational concepts that guide the development of the Common Agreement. The TEF includes such abiding principles as standardization, transparency, cooperation and non-discrimination, privacy, security, and safety, as well as patient access and population-level data.
  • The Minimum Required Terms and Conditions (MRTCs) Draft 2: Mandatory terms and conditions that QHINs voluntarily agree to follow. The Common Agreement will include the MRTCs, as well as additional required terms and conditions developed by an industry-based Recognized Coordinating Entity (RCE) that will oversee implementation and adherence to the Common Agreement. The MRTCs include requirements around such things as data quality and minimum necessary. Other terms and conditions found in the MRTCs align with the principles set forth in the TEF.
  • The QHIN Technical Framework (QTF) Draft 1: This document is incorporated by reference in the Common Agreement. The QTF details the technical and functional requirements for interoperability among QHINs, including specification of the standards QHINs must implement to enable QHIN-to-QHIN exchange of information.

In its comments, AHIMA supports the Framework’s call for adherence to applicable standards for EHI and interoperability that have been adopted by the Department of Health and Human Services, approved for use by the Office of the National Coordinator for Health IT (ONC), or identified by ONC in the Interoperability Standards Advisory.

AHIMA also agrees with ONC’s recommendation that QHINs should ensure that data exchange within their own network and with other QHINs meet minimum quality standards by using testing and onboarding programs to verify minimum quality levels, including ONC’s Patient Demographic Data Quality (PDDQ) Framework to evaluate the quality of patient demographic data. AHIMA also supported the requirement that QHINs must annually evaluate their patient demographic data management practices using the PDDQ Framework.

AHIMA also supports the requirement under Draft 2 of the Framework that a QHIN and their Participants should follow certain privacy practices including the provision of a written privacy notice in plain language similar to ONC’s Model Privacy Notice. This is critical because some QHINs may be a non-HIPAA entity and are therefore not required to provide a notice of privacy practices under HIPAA.

AHIMA has long advocated that consumer access to their health information is essential to improving health and healthcare, and in its comments highlights its continued support for efforts that enhance the ability of healthcare consumers to access their health information while improving the workflow for the health information management professionals who are often tasked with fulfilling those requests.

Finally, with respect to a question posed by ONC as to whether QHINs should meet a minimum acceptable patient matching rate and/or whether QHINs should measure and report on the performance of the algorithm(s) they rely on, AHIMA recommended that ONC and the RCE work with QHINs, Participants, and Participant Members to develop consensus minimum performance standards prior to implementation of such a requirement. AHIMA suggested that this reporting could help shed further light on the extent of the variation in patient matching algorithms, identify gaps as they relate to certain patient populations (including homeless and pediatrics), and help drive innovation in improving algorithm performance.

To read AHIMA’s comment letter, click here: http://bok.ahima.org/PdfView?oid=302772

Lesley Kadlec (Lesley.Kadlec@ahima.org) is director, policy and state advocacy engagement at AHIMA.
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