Industry groups have plenty to say about the draft Trusted Exchange Framework and Common Agreement (TEFCA) released by federal officials last month, but several reoccurring concerns emerged, including a timeline that many perceive as rushed.
The need for a “step-wise approach” that includes pilot testing was a chief concern for the Electronic Health Record Association (EHRA). In comments (PDF) to the Office of the National Coordinator for Health IT (ONC) the group worried that the TEFCA calls for “aggressive timeframes” without providing details about testing mechanisms or coordination with stakeholders.
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The framework calls for Qualified Health Information Networks (QHINs) to implement the voluntary framework within 12 months. EHRA also worried that the additional costs associated with being a QHIN could “disincentivize participation.”
“Overall, we are concerned that the proposed approach does not continue to build on the current state, but rather suggests a drastic change from diverse, yet increasingly connected architectures to a singular, monolithic architecture in a very short time period,” the group wrote.
Already started reading through the comments we've received so far on #TEFCA. You have 13 hours and 50 minutes to get your comments in. Keep 'em coming!
— Genevieve Morris (@HITpolicywonk) February 20, 2018
Likewise, the Sequoia Project urged (PDF) ONC to adopt a “phased and modular implementation of the TEFCA” managed by a Recognized Coordinating Entity (RCE), a private sector organization selected by ONC to oversee the implementation of the framework. The group also requested the agency plan for a transition period for TEFCA implementation to proceed alongside existing exchange initiatives in order to minimize disruption.
HIMSS also encouraged (PDF) ONC to adopt a phased-in approach to implementation, noting that the timelines for the TEFCA and the U.S. Core Data for Interoperability guidance will be “challenging.” The American Medical Informatics Association (AMIA) recommended (PDF) a three-year implementation plan that features specific pilot tests.
The College of Healthcare Information Management Executives (CHIME) is among several groups that called for a bigger focus on pilot testing. The organization also worried that the draft framework is “aggressive and sharply limits thoughtful input by stakeholders.” Officials wrote (PDF) the RCE selection process—which ONC plans to announce this year—should be “unhurried” given the central role the RCE will play in implementation
Still waiting on information blocking
Several organizations also want to be able to review the ONC’s definition of data blocking before offering comprehensive comments on the TEFCA. CHIME, the American Medical Association (AMA) and DirectTrust advocated for an opportunity to comment on the framework again once ONC issues its data blocking regulation, which is expected in April.
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“We have found it hard to offer meaningful comments without a complete picture of the policy landscape,” CHIME officials wrote, adding that members have expressed concern that providers would be deemed data blockers if they don’t participate in TEFCA.
AMA noted (PDF) that the definition of information blocking is a “critical component missing from the draft TEFCA” and asked for more clarity about whether the framework would be leveraged as a means of enforcing information blocking violations.
Patient matching shortfalls
Several groups homed in on the issue of patient matching. The American Health Information Management Association (AHIMA) argued (PDF) that although sections of the TEFCA establish a floor for patient matching, those guidelines may not go far enough, and it remains unclear which entity will be responsible for back-end reconciliation of mismatched data.
CHIME pushed for ONC to modify and expand the data matching provisions outlined in the guidance to consider adding real-time patient alerts, principles for monitoring data matching performance and a push beyond basic demographics covered in the framework.
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Similarly, The Pew Charitable Trusts—which has made patient matching a research priority—wrote (PDF) that identification and data matching will be a key barrier to effective implementation. Pew encouraged ONC to select an RCE that can prioritize patient matching and serve as a “multi-stakeholder, trusted entity to identify more robust standards.”
The group added that demographic data identified in the TEFCA is insufficient for long-term progress and advocated for a framework that can easily adopt more sophisticated approaches to patient matching.