Sequoia Project Previews TEFCA Interoperability Infrastructure

The Sequoia Project, selected by the ONC as the Recognized Coordinating Entity (RCE) for implementation of the Trusted Exchange Framework and Common Agreement (TEFCA) interoperability infrastructure, has released Elements of the Common Agreement for stakeholder feedback.

The RCE will also host a webinar series to foster dialogue regarding key policy issues.

“The Sequoia Project, in its role as the RCE, is working diligently with ONC to prepare a draft Common Agreement,” Mariann Yeager, chief executive officer of The Sequoia Project, said in a public statement. “Engagement by potential QHINs and other stakeholders in the Common Agreement development process now is essential for successful implementation later.”

The Common Agreement will establish the “rules of the road” for data exchange under the TEFCA interoperability infrastructure among Qualified Health Information Networks (QHINs) and the QHIN Technical Framework (QTF), a draft of which was released on July 28, 2021 for stakeholder feedback.

“The Common Agreement’s overall goal is to establish a floor of universal interoperability across the country,” said Micky Tripathi, PhD, national coordinator for health information technology.

“The unique role of the non-profit RCE is the ability to bring together stakeholders from across the healthcare and health IT landscape to shape the final Common Agreement and realize our goal to begin sharing in 2022,” he continued.

The Common Agreement will be a legal contract that the RCE will sign with each QHIN. Some provisions of the Common Agreement will apply to QHIN participants, as well as sub-participants of those organizations via other agreements.

The Elements of the Common Agreement posted on the RCE website gives a preview of policies that the RCE plans to include in the Common Agreement.

The elements include: definitions; exchange purposes; participants and subparticipants; required flow-down provisions; TEFCA information and required information; governing approach to exchange activities under the Common Agreement; QHIN designation and eligibility criteria; cooperation and nondiscrimination; RCE directory service; individual access services; privacy and security; special requirements (including consent); and fees.

In addition to stakeholder feedback events, the RCE has reconvened the 2020 Common Agreement Work Group (CAWG), made up of potential QHINs, for evaluation of the planned Common Agreement policies.

The Sequoia Project welcomes stakeholder feedback on the Elements of the Common Agreement through October 21, 2021 through the online feedback form. The RCE also encourages stakeholders to attend the Common Agreement webinar series. Registration for the webinars is open on the RCE’s Community Engagement webpage.

In July, ONC announced TEFCA will go live in the first quarter of 2022.

“We need networks to be seamlessly connected with each other,” Tripathi and Yeager wrote in a blog post at the time of the announcement. “While the nationwide networks have made considerable progress in this area, cross-network exchange is still not frictionless, and most state/regional HIEs serve only their local markets and many are not connected to any other networks at all.”

The current lack of nationwide interoperability hinders care coordination, as providers often do not have access to a patient’s complete medical history for clinical decision support.

Tripathi and Yeager also noted that while some nationwide networks currently support data exchange among providers for treatment purposes, they exclude other critical use cases including public health reporting, patient access to health information, population health management, payment support, clinical research, and emergency response.

“The COVID-19 pandemic made abundantly clear that our clinical and public health systems live in different interoperability universes,” Tripathi and Yeager wrote.

For instance, public health authorities and individual clinicians cannot easily aggregate data to inform questions related to COVID-19 vaccination acceptance.