Just a few weeks ago, I was attending the ONC Interoperability Forum in Washington, DC in hopes an announcement would be made, or a timeline provided from the Office of the National Coordinator for Health Information Technology (ONC) regarding the 2000+ comments that were issued in response to the ONC’s Interoperability and Information Blocking Proposed Rule, and 100+ additional comments in response to draft 2 of the Trusted Exchange Framework and Common Agreement (TEFCA). While some great discussions were had on the future of interoperability, we left empty handed.  Don’t get me wrong, it was great to hear Don Rucker, MD, National Coordinator for Health Information Technology, recognize DirectTrust™ for achieving 1 Billion messages exchanged since 2014, and big shouts out to Carequality and CommonWell Health Alliance® for their achievements in propelling query-based exchange forward. Still, many of us were leaning in for any indication on what to expect next.

I’m pretty sure there was an article in every major publication last week that covered ONC’s selection of The Sequoia Project as the Recognized Coordinating Entity (RCE) 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.

In addition to developing and updating the Common Agreement, the RCE will partner with ONC to designate and monitor Qualified Health Information Networks (QHIN). They will also modify and update accompanying QHIN technical requirements, engaging with stakeholders through virtual public listening sessions, adjudicating noncompliance with the Common Agreement, and proposing sustainability strategies to support TEFCA beyond the cooperative agreement’s period of performance.

What it all means
If you are feeling cross-eyed just reading this, let me take a moment to distill it down into some concise bullet points:

  • The Sequoia Project, in conjunction with Carequality and RTI International, was selected by ONC to become the RCE
  • Sequoia will work with ONC, and through convening industry stakeholder listening sessions, to develop the final TEFCA
  • The Common Agreement will include the required terms and conditions for participation in TEFCA-based exchange—the “Rules of the Road” providing governance to the framework
  • The QHIN Technical Framework will outline required technical specifications that all QHINs must support in order to ensure proper QHIN-to-QHIN exchange
  • Sequoia will be responsible for ongoing monitoring of QHINs, adjudicate noncompliance among QHINs, and implement processes for future updates to the Common Agreement
  • Sequoia will also drive future direction of the TEFCA, as it expands to include query-based exchange, push-based messaging, FHIR, among other forms of exchange in the future, as a single “on-ramp” for nationwide interoperability 

How this impacts Kno2 and our Partners
Kno2® has been involved with The Sequoia Project and Carequality from the beginning.  If fact, Kno2 sits among a list of original implementors of the Carequality Interoperability Framework, an initiative brought forth by the Sequoia Project.  Kno2 is highly involved with these groups, participating in both the Carequality Steering Committee and the Advisory Council, along with active participation in all Carequality workgroups: Push Notifications, FHIR, Document Content, Patient Queries, Authorizations, and also Sequoia’s latest initiative, the Interoperability Matters Leadership Council.

The good news…for you and for our partners…we will continue to stay involved. Under the current proposed TEFCA structure, Kno2 intends to be the QHIN for all of our partners. We will continue to advocate for you and our joint customers and the patients that are impacted by our ability to support simple and secure health information exchange.

If you have any questions, please feel free to contact Kno2.

Contributing Author:  Alan Swenson