Marching Forward: The Path to Operationalize TEFCA

Elise Sweeney Anthony; Liz Palena Hall and Mariann Yeager, CEO, The Sequoia Project (the TEFCA Recognized Coordinating Entity) | May 16, 2022

On January 18, the Office of the National Coordinator for Health Information Technology (ONC) and the TEFCA Recognized Coordinating Entity (RCE), The Sequoia Project, released the Trusted Exchange Framework and Common Agreement (TEFCA). The next key step for TEFCA is the release of resources to advance its operationalization, such as standard operating procedures (SOPs). These SOPs will include specific policies and procedures to further guide QHINs and will identify, where applicable, necessary technical implementation requirements.

Today, ONC and the RCE released the schedule for upcoming SOPs. In addition, the RCE has released an updated version of the QHIN Security Requirements for the Protection of TEFCA Information SOP, an initial QHIN Cybersecurity Certification List, draft versions of two additional SOPs, and the draft Application for Qualified Health Information Networks (QHINs). Links to materials are included below:

The SOPs and resources will provide more implementation details and will help potential QHINs, Participants, and Subparticipants make decisions regarding how they will leverage the network of TEFCA-compliant QHINs to meet their organizational goals. Additional input will be necessary to finalize some of the SOPs. The RCE looks forward to engaging with stakeholders to inform the development of those SOPs, including by receiving feedback on the RCE monthly calls (registration for the monthly calls can be found on the RCE website).

The publication of these materials will advance our steady progress toward realizing the TEFCA goals of establishing a universal policy and technical floor for nationwide interoperability, simplifying connectivity, and enabling individuals to gather their health care information. The SOP schedule is designed to make a set of SOPs available by August 2022. These SOPs will inform the application process for QHINs, which is set to begin in late summer/early fall. This is aligned with our goal of QHINs beginning to onboard as early as fall of this year.

We are excited about the broad interest and engagement among stakeholders in TEFCA and look forward to continuing to engage through upcoming educational webinars and outreach events. We look forward to supporting stakeholders as they prepare for TEFCA participation. And, be on the lookout soon for more information about upcoming plans for Health Level Seven (HL7®) Fast Healthcare Interoperability Resource (FHIR®) standards pilots, in alignment with our FHIR Roadmap for TEFCA Exchange.

For more information on TEFCA, please visit RCE.SequoiaProject.com, where you can register for the RCE’s upcoming webinars, download TEFCA documents and resources, and sign up for the RCE contact list.

TEFCA Standard Operating Procedures Release Schedule

SOP Name Summary Description Expected Publication of Final Version 1
1 SOP: QHIN Security Requirements for the Protection of TI (Update) Updates the SOP to include additional information regarding QHIN security certification requirements and a list of approved certification programs. Version 1.1 released today*
2 SOP: Exchange Purposes This SOP identifies the exchange purposes that are authorized under the Common Agreement (or in the SOP itself) and specifies which exchange purposes require responses. The Common Agreement authorizes the exchange purposes of treatment, payment, health care operations, public health, government benefits determination, and individual access services—these exchange purposes are available immediately when QHINs go live. Once an SOP for a particular exchange purpose is finalized, QHINs, Participants, and Subparticipants would need to support exchange pursuant to that SOP. June 2022*
3 SOP: RCE Fee Structure for QHINs (Schedule 1) Specifies the fee structure for fees charged to a QHIN by the RCE (initially such fees would be set at zero). June 2022*
4 SOP: Types of Entities That Can Be a Participant or Subparticipant in TEFCA Specifies the types of entities that can be Participants or Subparticipants. July 2022
5 SOP: QHIN Onboarding & Designation (and QHIN Application) Specifies the requirements QHINs must meet, including those needed to be eligible to apply for designation. August 2022
6 SOP: Means to Demonstrate U.S. Ownership and Control of a QHIN Specifies the Common Agreement policy regarding QHIN foreign ownership. August 2022
7 SOP: Individual Access Service (IAS) Provider Privacy and Security Notice Sets forth the implementation of the requirements in Common Agreement 10.3. August 2022
8 SOP: Individual Access Services (IAS) Exchange Purpose Implementation Specifies the expectations of IAS providers, including demographics-based matching and identity proofing. August 2022
9 SOP: Participant and Subparticipant Security Specifies security requirements for Participants and Subparticipants. October 2022
10 SOP: Other Security Incidents and Reportable Events Further specifies the Common Agreement’s definition of TEFCA Security Incident(s). End of 2022
11 SOP: Payment and Health Care Operations Exchange Purpose Implementation The Common Agreement itself specifies that payment and health care operations are authorized exchange purposes, meaning that they are available to be used by QHINs, Participants, and Subparticipants immediately when QHINs go live. This SOP will further define the parameters under which responses to queries are required for these exchange purposes. Early 2023
12 SOP: Public Health Exchange Purpose Implementation The Common Agreement itself specifies that public health is an authorized exchange purpose, meaning that it is available to be used by QHINs, Participants, and Subparticipants immediately when QHINs go live. This SOP will further define the parameters under which responses to queries are required for this exchange purpose. Early 2023
13 SOP: Government Benefits Determination Exchange Purpose Implementation The Common Agreement itself specifies that government benefits determination is an authorized exchange purpose, meaning that it is available to be used by QHINs, Participants, and Subparticipants immediately when QHINs go live. This SOP will further define the parameters under which responses to queries are required for this exchange purpose. Mid 2023
14 SOP: Suspensions Process Specifies requirements and timelines related to suspension per Common Agreement 16.4.1. 2023
15 SOP: Successor RCE & Transition Specifies processes and requirements if there is a change in RCE. 2023
*As a result of the significant input that already has been received throughout the TEFCA development process, these SOPs will be released in final form. All SOPs may be revised in the future and ongoing feedback on any SOP is welcome at any time.