By Dr. Chris Hobson, chief medical officer, Orion Health.
For nearly a decade, Health Information Exchanges (HIEs) have been looking for their long-term sustainable business model. This is part of the journey toward the future state of the HIE, which will be a ubiquitous healthcare utility that makes data available to all stakeholders across the healthcare landscape. Today, their work and future plans are driven by a desire to support value-based care initiatives, enhance interoperability, and leverage and manage a wider scope of data.
Representing a broad swath of HIEs, a 2019 Survey on HIE Technology Priorities uncovered various key trends and changing priorities in the sector. To become a sustainable healthcare information provider, HIEs must understand and leverage data to gain insights that improve patient outcomes while containing costs. Additionally, other trends include joining national exchanges, introducing value-added capabilities, enhancing integration of clinical and claims data, and growing payer participation in HIEs.
Participation in various national initiatives is an important driver for HIEs as it requires successful HIEs be more active across traditional geographic and state boundaries. Mechanisms for participation include the Trusted Exchange Framework and Common Agreement (TEFCA), the national eHealth exchange, Direct Trust and Carequality. Participation in Patient Centered Data Home, an event notification service that includes HIEs across the U.S. led by the Strategic Health Information Exchange Consortium (SHIEC), had the highest level of interest across all surveyed HIEs.
Like a utility, the next generation HIE must fit into the growing “Network of Networks” ecosystem, providing shared services to multiple HIEs (e.g. EMPI/record locator, patient directory, provider directory, data aggregation). This also means bringing together disparate entities into a local HIE network connecting a variety of different end-points – including practices, hospitals, systems, labs, long-term care facilities and more – while simultaneously making the local information shareable with other regional and national HIE networks. HIEs will need to support population-based use-cases and assist safety-net providers and small, independent providers to access larger interoperability initiatives across the U.S., such as TEFCA and the e-Health Exchange.
The Office of the National Coordinator for Health Information Technology (ONC) announces that The Sequoia Project has been awarded a cooperative agreement to serve as the Recognized Coordinating Entity (RCE). The RCE will be responsible for developing, updating, implementing, and maintaining the Common Agreement component of the Trusted Exchange Framework and Common Agreement (TEFCA). The Common Agreement will create the baseline technical and legal requirements for health information networks to share electronic health information and is part of ONC’s implementation of the 21st Century Cures Act (Cures Act).
“The Sequoia Project was selected through a competitive process to help with the interoperable flow of health information. We look forward to working in close collaboration with The Sequoia Project and across the broader health system to create a Common Agreement that best serves the needs of all stakeholders,” said Don Rucker, MD, National Coordinator for Health Information Technology.
In the Cures Act, Congress directed HHS to advance trusted exchange of electronic health information among health information networks through the Trusted Exchange Framework and Common Agreement. The Cures Act’s focus on trusted exchange is an important step toward fostering transparency and competition throughout the healthcare delivery system by addressing the technical barriers and business practices that impede the secure and appropriate sharing of electronic health information.
In addition to the Common Agreement, the RCE will collaborate with ONC to designate and monitor Qualified Health Information Networks (QHIN), modify and update accompanying QHIN technical requirements, engage with stakeholders through virtual public listening sessions, adjudicate noncompliance with the Common Agreement, and propose sustainability strategies to support TEFCA beyond the cooperative agreement’s period of performance.
“We have learned through our own operations that seamless nationwide sharing of health information is most readily enabled through trust agreements, consistent policy and technical requirements, and appropriate, balanced governance to provide assurance of trust and interoperability. We look forward to working alongside ONC as the Recognized Coordinating Entity,” said Mariann Yeager, CEO of The Sequoia Project.
One of the greatest challenges in healthcare is keeping up with the changing landscape. Considering only since the beginning of 2019, the Centers for Medicare and Medicaid Services (CMS) and other federal agencies, such as the Office of National Coordinator of Health IT (ONC) and the Department of Health and Human Services (HHS), have introduced a number of rules as a measure of upholding their goal of empowering patients and enhancing healthcare efficiency. We’re at a very critical juncture in healthcare and from a regulatory perspective, there are a few key rules that merit a special focus which will have a great impact from both a clinical and financial standpoint.
The MyHealthEData Initiative in 2019
The MyHealthEData initiative, launched in March 2018, aims to “empower patients by ensuring that they control their healthcare data and can decide how their data is going to be used, all while keeping that information safe and secure.” Only a few days back, CMS upped the ante for better data access by expanding this initiative and announcing the pilot of “Data at the Point of Care.”
The Data at the Point of Care (DPC) pilot will be connecting providers with Blue Button data, where providers can access claims data to learn more about their patients and their previous diagnoses, procedures, and prescriptions. While providers had to comb through several hundred data sets previously, the DPC program would aim to make access to data easier and right within their workflows.
This announcement follows the relaunch of the Blue Button initiative, or Blue Button 2.0, that grants access to health data and enables patients to send that information using FHIR-based healthcare apps.
In a nutshell, these moves come as an overall push from CMS to promote better access to data and 100% healthcare interoperability. In addition to enabling data access, CMS has also been targeting information blocking, as reflected by 2019 MyHealthEData updates. With these measures, both patients and providers will have the required insights to make more informed healthcare decisions.
The Trusted Exchange Framework and Common Agreement
In April 2019, ONC published its second draft of the Trusted Exchange Framework and Common Agreement (TEFCA), focusing on three high-level goals:
Providing a single ‘on-ramp’ to nationwide connectivity
Enabling Electronic Health Information (EHI) to securely follow the patient wherever needed
Supporting nationwide scalability
TEFCA is basically a common set of principles which serve as “rules of the road” for nationwide electronic health information exchange across disparate health information networks (HINs). The framework, which was mandated by the 21st Century Cures Act, provides a set of policies and procedures along with technical standards required to enable healthcare data exchange among providers, state and regional HINs, and federal agencies.
The U.S. Department of Health and Human Services (HHS) today issued for public comment draft two of the Trusted Exchange Framework and Common Agreement (TEFCA) that will support the full, network-to-network exchange of health information nationally. HHS also released a notice of funding opportunity to engage a non-profit, industry-based organization that will advance nationwide interoperability.
Specifically, the documents being released for comment are: (1) a second draft of the Trusted Exchange Framework (TEF), (2) a second draft of the Minimum Required Terms and Conditions (MRTCs) for trusted exchange, and (3) a first draft of a Qualified Health Information Network (QHIN) Technical Framework. These documents will form the basis of a single Common Agreement that QHINs and their participants may adopt. This Common Agreement will create baseline technical and legal requirements for sharing electronic health information on a nationwide scale across disparate networks.
“The seamless, interoperable exchange of health information is a key piece of building a health system that empowers patients and providers and delivers better care at a lower cost,” said HHS Secretary Alex Azar. “The 21st Century Cures Act took an important step toward this goal by promoting a national framework and common agreement for the trusted exchange of health information. We appreciate the comments and input from stakeholders so far and look forward to continued engagement.”
In developing a TEFCA that meets industry’s needs, HHS’ Office of the National Coordinator for Health Information Technology (ONC) has focused on three high-level goals:
Provide a single “on-ramp” to nationwide connectivity;
Ensure electronic information securely follows you when and where it is needed; and
Support nationwide scalability for network connectivity.
ONC will maintain the TEF, while a non-profit, industry-based organization, known as the Recognized Coordinating Entity (RCE), will be awarded funds to develop, update, implement, and maintain the Common Agreement. Through this effort, ONC will define the minimum required terms and conditions needed to bridge the current differences among data sharing agreements that are preventing the flow of electronic health information. The industry-based RCE will be tasked with developing additional required terms and conditions necessary to operationalize the Common Agreement and meet the interoperability requirements of the 21st Century Cures Act.