Sequoia Project Says TEFCA Must Avoid Disruption, Duplication

The Sequoia Project urged the Office of the National Coordinator for Health IT (ONC) to be mindful of the intent that the Trusted Exchange Framework and Common Agreement (TEFCA) second draft avoid disruption and duplication of “existing exchanges between participants of health information networks,” according to a letter submitted to Don Rucker, M.D., National Coordinator for Health IT.

The U.S. Department of Health and Human Services issued a second draft of TEFCA to support full interoperability of health information from network to network. The second draft is designed to scale electronic health information exchange nationwide. The draft also aims to ensure that health information networks, healthcare providers, health plans and stakeholders have secure access to their electronic health information whenever and wherever it is needed.

The Sequoia Project is a nonprofit dedicated to advancing secure, interoperable health information exchange.

The Sequoia Project Recommendations

According to comments in the letter, TEFCA would disrupt and duplicate exchange mechanisms that would require extensive changes to existing activities and revisions to the terms of thousands of legal agreements. The Sequoia Project members want ONC to minimize or eliminate duplication and disruption, especially in the need to revise legal agreements.

The group recommended ONC provide definitions for the revised exchange purposes in the final TEFCA definitions that say case management and care coordination are required exchange purposes. Sequoia Project members want the payment and healthcare operations defined by the Health Insurance Portability and Accountability Act (HIPAA) to be included as exchange purposes under the framework.

They asked ONC to be more explicit with how fees charged by participants and members are handled as part of the common agreement, including fee limits and transparency requirements.

What the Sequoia Project Supports

The Sequoia Project supports ONC’s goals for the framework, which include:

• A single “on-ramp” to nationwide connectivity
• To enable that electronic health information securely follows the patient where and when it is needed
• Support nationwide scalability

The members strongly support the proposal that the Qualified Health Information Network (QHIN) technical framework would be incorporated by reference in the common agreement and finalized by the recognized coordinating entity.

The group believes TEFCA can add value in harmonization of agreed upon purposes for exchange and use of information. They wrote that the framework should address material gaps in current exchange networks, frameworks and agreements.

The letter said the Sequoia Project members strongly agree with ONC that baseline privacy and security requirements shared by all QHINs, participants and members is important to build and maintain trust that the health information is protected. But the group urged the agency to be clear when non-HIPAA covered entities must meet all HIPAA privacy and security protections.

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