The draft Trusted Exchange Framework and Common Agreement released by federal officials earlier this month is a “noble” and necessary effort to simplify the complexities of interoperability, according to one HIMSS official. But he worries that the potential implementation costs will trickle down to patients.
In a blog post, Jeff Coughlin, HIMSS senior director of federal and state affairs, wrote that the new guidance provides “an infrastructure to move forward and ensure that more stakeholders can fully participate in data exchange.” The guidance leans on the concept of creating a single-on ramp using existing market approaches to data exchange.
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That approach is beneficial to minimize market disruption, Coughlin says, but it also adds new complexities to for the industry, particularly when it comes to updating and revising participation agreements and supporting additional permitted disclosures.
“I would characterize participation agreement revisions in the short-term pain for long-term gain category, but if the market moves in the direction that ONC is intending and only a small number of qualified HINs (~10) come into existence, there will be a lot of work that has to occur to update these agreements across the entire community,” he wrote. “The goal of a single on-ramp to exchange is a noble one, but can only be actualized at the conclusion of a complex path.”
That complex path could mean additional costs for the health information networks that decide to participate—costs that may trickle down to providers and ultimately patients.
Genevieve Morris, ONC’s principal deputy national coordinator who is spearheading TEFCA, has said the guidance was built to reduce the number of point-to-point interactions that are driving up costs across the system. She noted that framework “is just the floor” for required terms and conditions and that a coordinating entity identified by the agency will be responsible for providing more definition around the specifics.