The Royal Court Arrives

First-Round of QHINs Receive Certificates of Recognition

The Office of the National Coordinator for Health Information Technology has finally begun to make strides on industry-wide interoperability with the Trusted Exchange Framework and Common Agreement (TEFCA) that was part of the 21^st Century Cures Act (Section 4003(b) – PDF). This “framework and agreement” aims to achieve data liquidity that will drive the seamless exchange of electronic health information between the varied technology platforms and healthcare organizations that need to communicate with each other – while being sure to promote privacy, security, and transparency. Utilizing a standardized framework will maintain transparency and reduce the cost and burden of sharing data across various healthcare organizations.

The foundation of TEFCA is a cohort of Qualified Health Information Networks (definition of QHINs from Sequioa Project) , which ensure that healthcare data is shared consistently and reliably, allowing providers to access patients’ information in real-time. Recently, we’ve taken a giant leap toward the vision of interoperability that will drive better healthcare outcomes with the certification of the first cohort of QHINs.

As of February 13^th, 2023, Secretary Xavier Becerra has bestowed the following organizations with certificates of recognition, formally confirming them as QHINs: Commonwell Heath Alliance, eHealth Exchange, Epic, Health Gorilla, Kno2, and KONZA.  Becerra asserts “that TEFCA would bring down the cost of healthcare, benefit patients and support providers. Interoperability provides better connections for patient care, reduces the risk of medical errors, and prepares America for future healthcare crises.” As the old phrase goes, heavy is the head that wears the crown, and that couldn’t be more true for these six entities with this first-of-its-kind, weighty responsibility.  The future of efficient data exchange lies within these six organizations.

The Trek to QHIN Status

The road to QHIN status was long; all six entities were required to fulfill the eligibility requirements, sign the common agreement, complete an onboarding process, and then formally apply for QHIN status. The ONC released the final TEFCA documentation on January 5th, 2022, and one of the most significant changes in the final rule included a single onboarding process for the entities that were seeking QHIN status; this includes guidelines for the development of a certification program intended to promote accountability and transparency amongst participating organizations.

In addition, the final product had an additional requirement: prospective QHINs utilize USCDI (U.S. Core Data for Interoperability) to guarantee that these organizations use a standardized set of data elements to mitigate potential data exchange errors. These entities had to get their ducks in a row, as seeking QHIN status is a lengthy and tedious process (with good reason).

Are We Viewing TEFCA Through Rose-Colored Glasses?

Even though this is a significant moment for these six entities, TEFCA is still met with much criticism and skepticism, as various challenges still need addressing to ensure that it fulfills its intended purpose. Competing healthcare organizations are concerned that this will create even more competition amongst the organizations vying for QHIN status versus those already appointed. They fear this could impede innovation and cooperation, especially with smaller organizations.

Although one of the main goals of TEFCA is to promote transparency, many organizations are reluctant to share patient information with other healthcare organizations, given very legitimate concerns about privacy, security, and general liability. A common misconception is that once these healthcare organizations obtain QHIN designation, they can kick back and enjoy the fruits of being a QHIN. That assumption couldn’t be further from the truth – it took a lot for them to get here, and it’ll take even more work to stay in the mix.

QHINs are required to remain in compliance with TEFCA requirements, which is a whole other beast. To stay compliant, these entities must fulfill the criteria covering various nuances of data exchange ranging from security, data standards, and privacy — which is costly. In addition, these 6 QHINs must continue to invest in personnel, technology, and training, which could become a potential barrier for smaller organizations with limited resources. The sustainability and longevity of TEFCA are reliant on the widespread adoption of key players (hospitals, clinics, and providers) and patient participation. Stakeholders must be open to collaboration if this is going to have the impact that we’re all hoping for.

All in all, we are watching this concept that the health IT space has been ruminating on for years come to life, and it begins with these 6 QHINs. The fate of TEFCA is currently relying on a mere six organizations to drive the next evolution of health data liquidity. It has the potential to propel interoperability to new heights, or it could crash and burn miserably like so many other attempts at implementing enterprise technology standards. The momentum and interest are there, but will we see more QHINS added to the fold? Only time will tell.