In a February 20, 2018 letter to National Coordinator for Health Information Technology, Donald Rucker, HIMSS offered comments to the Office of the National Coordinator for Health Information Technology (ONC) in response to the Trusted Exchange Framework and Common Agreement (TEFCA) Draft Guidance. In this letter, HIMSS leverages its members’ expertise in offering feedback on the Framework, and they look forward to a continued dialogue with ONC on interoperability within the healthcare IT community, especially around implementation of the various provisions included in the 21st Century Cures Act.
HIMSS appreciates the work undertaken by ONC and its stakeholders to create this draft guidance document. The effort to minimize the point-to-point interface agreements required in the long-term and the flexibility for providers to find the right exchange network that supports their care delivery model needs is the right approach. The overall concept underlying TEFCA is pushing our nation in the appropriate direction of enabling providers and communities to deliver smarter, safer, and more efficient care; promoting innovation at all levels; and, achieving a system where individuals are at the center of their care and where providers have the ability to securely access and use health information from different sources.
HIMSS proposes in the letter to maintain the role of the Recognized Coordinating Entity (RCE) and its current duties in the proposal, but would like to see changes around what is required of QHINs as well as the eligibility requirements for Qualified Health Information Networks (QHINs). HIMSS looks to find a path forward that allows existing interoperability exchanges, networks, approaches, and frameworks to largely continue to function under their existing business models, qualify as QHINs, and have them report to the RCE as the primary oversight mechanism of TEFCA.
Given the voluntary nature of TEFCA, HIMSS endorses the idea that future regulatory policy levers utilize the Framework to support its goals and increase the long-term sustainability of the Framework overall.
HIMSS recognizes the value of US Core Data for Interoperability (USCDI) and data classes identified in the draft guidance and aspires to an environment where exchange participants have all these data classes available and ready to share. In order to increase the likelihood of engagement, HIMSS recommends a phased-in approach.