Bill Russell: 00:09 welcome to this week and health it news where we look at as many stories as we can in 20 minutes or less that are going to impact health. It is Tuesday News Day. And here's what we have on tap. The ONC awards, the Sequoia Project as TEFCAs recognized coordinating entity. You know, sometimes I, I pick a story and I realize I'm going to just dig in because I want to know more about Tefca. I want to understand where it's at, when it's going to impact health, it, what are some of the ancillary things around it. And, uh, so that's what I did. I looked at a handful of stories on this, uh, from the impact advisors site. TEFCA in a nutshell, nutshell, part two. Um, took a look at the a US core data for interoperability, uh, work that was going on USF, uh, health online, uh, onc and seen CMS proposed rules, so forth and so on.

Bill Russell: 01:00 I read a bunch of government stuff this weekend and I thought I would, uh, share with you what I've learned around TEFCA. So this is going to be the TEFCA episode. Uh, I'm sure I'll revisit it again. I've reached out to uh, um, the onc and, uh, would like to get somebody from the onc on the show to talk to this, uh, more in detail on a Friday episode. So, uh, my name is Bill Russell, recovering healthcare CIO and creator of this week in health. It a set of podcast and videos dedicated to developing the next generation of health it leaders. This podcast is sponsored by health lyrics. Professional athletes have coaches for every aspect of their life to improve performance. Yet many CEOs and health executives choose to go it alone. Technology is taking center stage in healthcare, get coach in your corner. Visit healthlyrics.com To schedule your free consultation.

Bill Russell: 01:48 Uh, finally check out our two new free services. Uh, we have this week health, uh, insights in this week health staff meeting insights is for individuals looking to propel their career forward. A staff meeting is for managers who are looking for a way to introduce their staff to some new thinking and get the conversation started in the right direction. If either of those are of interests, hit the website, hit subscribe, and you can subscribe right there and a lot of you already have. And it's a, it's a lot of fun developing those videos for you to get that delivered to your inbox. So let's get to the news. Uh, now before we get into TEFCA and where it's going and whatnot, this is not an endorsement of this approach or a direction I, as you've heard, if you've listened to the show for any period of time, I'm really more of a patient mediated exchange kind of person.

Bill Russell: 02:37 I believe that, uh, that would be a better mechanism. They would be more a viable long run. I think it would be a less intrusive long run. I think there'd be a, it would move faster. I think it would, uh, ride on the coattails of the market and, uh, I think it would have more value to the patient. And in the end, I think it would a much better solution. With all that being said, I'm off my soap box. We're going to talk about TEFCA. Let's see, uh, where it's going. So here's, here's what's coming. Here's where TEFCA sorta comes. It comes out of the 21st century cures act, which was sometime around December, 2016. This will give you an idea of how this is not exactly moving very quickly and you might get fall into a false sense of security that you don't have to do anything around it.

Bill Russell: 03:24 And, uh, I'm not sure that's the case. It is moving slowly, but it's a, it's getting there. It's starting to form. We're starting to see, uh, what's going to happen. So 21st Century Cures Act 2016 had something in there called, um, uh, information blocking, which, uh, many people struggle to really understand. And there was a lot of back and forth of what information blocking, uh, really meant. And we'll go into that in a little a little later. It's still a little vague, but I think it's starting to crystallize, to be honest with you, of what that's gonna look like. Uh, let's see. January 5th, 2018, health and human services released the draft specification for TEFCA trusted exchange framework and common agreement. Okay. So it has really two, two parts of it, the trusted exchange framework and a common agreement that once final, we'll define standards for interoperability as required by the 21st century cures act.

Bill Russell: 04:15 Uh, April 19th, 2019. Oh, by the way, the person who wrote this article did a phenomenal job. Um, and it's on the impact advisor site. Dan Golder, uh, wrote a handful of these and just exceptional articles. You should check them out. Impact advisors site. They have a lot of good articles for this. This, this is really exceptional. Uh, April 19th, 2019 health and human services released as long awaited, updated update to TEFCA. The prose rule builds on a what HHS earlier. So, so what is it? Uh, we sort of talked about this TEFCA strives to establish a single on ramp for the sharing of data. Um, it will enable providers, hospitals, and other healthcare stakeholders read into that, uh, quite frankly, patients and payers and, and other entities, uh, to join any health information network and then automatically connect and participate, uh, in nationwide health information exchange. Uh, onc stated goals are for TEFCA.

Bill Russell: 05:15 Our provide a single on ramp, uh, to nationwide connectivity. Electronic Health, uh, information securely follows the patient when and where it's needed, uh, and supports a nationwide scalability. I listened to a couple podcasts on this and, uh, people were just going off on, you know, if there was a business case for this, it would have been developed. Uh, and the answer to that is, uh, there are business cases to be developed. They just do not benefit the, uh, the people who hold the, uh, cards. I'll give you a, you know, here's, here's my example. We, uh, wanted to share information across our entire health system. So we were in northern California, southern California, and West Texas. And, uh, at the end of the day, we did the research and realized that a number of people from west texas that ended up in one of our facilities in southern California was so minuscule over the course of close to a 20 year period, uh, millions of patients.

Bill Russell: 06:11 It was so minuscule. I mean, it was in the, it was less than a hundred that had made that, uh, that track. And so from a business case standpoint, did it really make sense for me, it's the CIO to make sure that we were sharing data effectively between West Texas and southern California. Um, and some people can make the case, you know, and they have on the podcast or making the case on, um, Kaiser, you know, doesn't really share information really effectively between Maryland and southern California. Um, and again, the cases, you know, if there's no business case there, well here's the business case. I mean, the business case is that there's a ton of people in Silicon Valley right now who are looking to get access to this data that they can start to innovate around the patient experience around the patient. Well, the power for brokers and stake holders, they really don't want silicon valley to innovate, quote unquote.

Bill Russell: 07:02 Um, and we can argue that we can go back and forth, but the powerful, uh, are the EHR providers. It's the, it's quite frankly, it's everybody. It's everybody who has an established business. And we're not talking about small business here is we're talking about billions and billions of dollars in, in businesses. The, uh, the providers don't really have a, uh, an incentive to, uh, to share the data of much except in their local markets where they're trying to build out clinically integrated networks. And, uh, you know, do I really need to share my data with Northern California, with Oregon, with others? Um, you know, it doesn't make sense. And quite frankly, with the cost of healthcare, I'm the class of running it with, in healthcare today. Am I going to, you know, rise this up to the level of, say, creating a new consumer experience? It's probably not, to be honest with you.

Bill Russell: 07:49 So I'm not going to be spending that kind of money. There's a lot of, of me, and let me get back to the, the TEFCA at this point. So they're trying to, they're trying to share data across a broader spectrum. Um, and again, to close out that case, my case is that if the data was available to more entrepreneurs in less cost to them, because right now they have to pay certain entities to get access to that data. So then they, they, it slows them down first of all to get access and second of all it costs more money for the solutions that they're developing. And you know, TEFCA and onc they're trying to say, hey, you don't have to pay for the data. And um, because you don't have to pay for the data. And they also want to make it available. A case can also be made that if the providers were able to make money as opposed to the EHR providers making money from the sharing of data, that there would be more of a market because I would look at my health system.

Bill Russell: 08:43 And so that's our sharing data anyway. Let's take a look at, so exchange purposes have been updated and this was a, this article is probably in June or something to that effect. So HHS is defined and broaden a specific set set of payment and health care operation purposes for TEFCA. Um, and that is treatment benefits, determination, quality assessment and improvement, business planning and dual element, public health utilization review and individual access services. So TEFCA, uh, defined some business cases around why you would want to share this data. There they are, uh, how this is gonna work is you're going to have the qualified, what do they call it, the qualifying entity. What was Sequoia was named, the, uh, recognized coordinating entity, the RCE and then you're gonna have qualified health information, uh, networks, which are going to be the subsets with, uh, that are, uh, sharing information across the national network.

Bill Russell: 09:44 So the, a qualified health information networks are going to, uh, have a handful of ways that they're sharing data. They're going to share data, uh, they're going to do broadcast query targeted queries, message delivery, or a push. So well, here's what they look like. Request for our patients. Ehi from all, uh, QHINs. Uh, that's the broadcast targeted query is request the patient's Ehi from a specific QHIN and then a push is QHIN delivery of a patient's Ehi to one or more specific QHINs. So they're starting at a, you're starting to see this, um, materialize in terms of how they're, um, how they're going to govern it, how they're willing to, uh, how it's going to be designed. And then, uh, what, uh, how the data is going to be moved around the, uh, qualified health information networks. So, uh, security requirements for exchange.

Bill Russell: 10:42 All right, so they're, they're starting to put together the security requirements for exchange. This is one of the major push backs of a TEFCA and other things that are coming down from onc and CMS, which is, hey, you know what you're telling us, we have to share the data. You're not, you're, you're not giving us, uh, uh, you're not telling us how it's going to be protected. Well, um, you know, they have, uh, they have a handful of things and a lot of specifications. I'm not going to go into them. They're using this, they're using a, Oh gosh, they're using a bunch of different specifications that have been used in the federal government in other areas. Uh, identity proofing, user authentication, breach notification, uh, Ehi disclosure outside of the u s meaningful choice, uh, security labels and so forth. So they have to find a set of security requirements.

Bill Russell: 11:29 There's still more, I think, more work to be done in this area, but, um, but they are defining the a security. So I'm saying all this to say this is starting to move a little faster. I don't think there's a ton of work for us to do today around TEFCA per se, but, uh, if you are a provider, but there is a, you need to be aware of it. You need to know where it's going and you need to know what they're trying to accomplish and they're trying to accomplish the, uh, the sharing of certain data today, uh, across the entire nation. And then the ability to, uh, make changes not make changes, the ability to expand the data that is going to be shared. I'm going to share a little bit later of what data, uh, they're looking at sharing. So, uh, qualified, let's go into this a little bit.

Bill Russell: 12:16 So how does it work? The qualified, uh, networks, um, are a vehicle to help facilitate standardized methodology for HIE interconnectivity along with a new administrative organization, the recognized coordinating entity, which was, uh, given to, um, the s Corp project, which is not a real huge shock to anyone, uh, given their, uh, their work to date, uh, in this space. In fact, uh, I hadn't read anywhere where someone was surprised that that is who, uh, who it was awarded to. So, uh, let's, let's break this down. A trusted exchange framework. So standardization, transparency, cooperation and non-discrimination, a privacy, security and safety access population level data, so that the trusted exchange framework establishes a, again, based on the 21st century cures act, uh, represents a set of six common principals serving as rules of the road for information exchanges that are designed to facilitate trust among the a HINs

Bill Russell: 13:21 And by the way, your HIE today, your, your regional HIE in the HIEs you're in today. Uh, they will have to apply to become qualified health information networks and some may do that because there's a funding and money associated with it and some may not. Um, I'm not sure why they wouldn't, but some may not for a reasons that aren't apparent to me yet. As I'm reading this stuff. And by the way, I would really encourage you to do your own research at this point. What you're getting from me is a dump of what I, uh, went through this weekend and podcasts I listened to and things I, I've, I've gone tried to just try to go deep in this one area, uh, which is what I do every now and then when something big comes along just to make sure that, uh, I can be coherent and participate in the conversation.

Bill Russell: 14:10 So, standardization, transparency, cooperation and non-discrimination, privacy, security and safety access and population level data. So those are the, uh, six common principles for the trusted exchange framework. Now that's TEF. The CA is common agreement. The common agreement establishes the governance necessary to scale Tifca the proposed architecture, uh, will allow stakeholders the opportunity to participate as participants. Participant members or individual users. The common agreement, furthermore promotes public private partnership with HHS and will administer three layers of governance necessary. Just scale the proposed system of connected HINs and qualified health information networks. They have the minimum required terms and conditions, additional required terms and conditions and the uh, qualified health information network. Technical framework. Uh, let's see, I'm going to, I'm going to pick up the pace a little bit here. You've got about five minutes ago. So the recognized qualifying a coordinating entity. So this is important now because now that's been, uh, is, is, uh, now it's been awarded.

Bill Russell: 15:16 So the rces third leg of the TEFCA's stool and we'll establish a public private partnership for HHS in that it will private, it will be privately owned entity, competitively selected by HHS and administer TEFCA. So the RCE will administer TEFCA and it will have responsibility for virtually all of the key components of for administration and implementation of TEFCA, including developed an update and implement and maintain the common agreement identified, designated and monitor a qualified health information networks, modify, uh, and update the information network technical framework. A virtually convened public listening sessions, develop and maintain the process of adjudicating a qualified network compliance and proposed strategic, uh, strategy to stay in the common agreement at a national level after the initial cooperative agreement period. So a, those are some of the things that the sequoia project is going to be doing.

Bill Russell: 16:15 So, um, you know, why is the RCE important? Because quite frankly, they're at the center of this whole thing. They're going to administer it and they're going to, uh, make the whole thing sort of work. Um, now with all that being said, you, you might think, wow, this is really coming fast. Well, it is, and it isn't. And Sequoia's been, uh, adopted, you know, what are some of the next things that are going to happen? Uh, let's see. Onc is targeting the first draft of the common agreement for the spring of 2020. So the common agreement, it hasn't been specified and won't be specified until the spring of 2020. If everything goes well. There's a lot of people, a lot of, there's a lot of entities to bring together to have conversations. Uh, you have to worry about, um, not doing anything that's going to disrupt the current, uh, sharing, uh, mechanisms that are already in place.

Bill Russell: 17:05 And, uh, the progress that's already been made. You have some, uh, legal work obviously to do here and um, and uh, you, you want to get buy in, you want to get as much buy in as possible. So there's a lot of entities, a lot to do. Uh, so the draft of the common agreement, uh, we're looking at 2020. Let me get back to the a US core data for interoperability. USCDI. So, uh, what is the USCDI? This USCDI is, um, is the, uh, is providing the standards around what data needs to be shared and how it, how it's going to be shared. So, uh, interrupt interoperable this from a different story. This is from the USF health online interoperability requires a technical framework of hardware, software, and of course information each of these issues surrounding it, but the ladder, each of these has issues surrounding it.

Bill Russell: 18:00 Put the ladder is an area that the onc for health, it is seeking consensus on in order to create standardized data sets that all electronic health records will contain the u s CDI initiative from the onc aims to develop a minimum set of data classes that will be required to be interoperable on a national scale and implemented by the end of 2018. This, it's like this pitch is coming a little faster. So, uh, the data classes are meant to be iterative and expand strategically over time. Additional classes are being identified for implementation in 2019 to 2020. In other words, the U S Cdis goal is to establish what information all electronic health records systems should be able to share no matter where you are in the United States. And then matter what differences exist between the systems and services providers of any given health facility. The USCDI has built in task force, the goal of which is to make recommendations about drafts of the policy and it is proposed expansion process as well as incorporated stakeholder feedback.

Bill Russell: 19:04 And some of our listeners are on that task force and we're going to have a guest, uh, in the not too distant future who is also on that task force. So, um, you know, and it just goes on to talk about, you know, why the standards and whatnot. If you have done any interoperability and data sharing work in healthcare, you understand why there's a standards needed. Now the good news is they're not coming up with new standards. What they're defining is what the data is that's going to be shared. And it's, you know, it's pretty standard stuff. If you set up a, a clinically integrated network, it's standard stuff. You're going to see a demographics. Um, some, uh, let's see.

Bill Russell: 19:45 Yeah.

Bill Russell: 19:46 Wow. That's small. Let's see. I wish I could blow that up. I think it's listed somewhere else. Well, okay, I'll try to read it. I don't have it listed somewhere else. So it's mostly demographics. You have some, uh, oh, I have a graphic over here. Much better. Let's go to the graphic.

Bill Russell: 20:06 No, no, not that much better. I apologize. So, um, let me see. Here's what we have. Patient name, date of birth, race, smoking status, laboratory value, results, problems, medication allergies, care team members, immunizations. unique device identifiers for a patient's implantable device. That's important. Obviously providence. So that's something new that's essentially just giving us, you know, who's working on the record. Um, sex, preferred language, ethnicity, uh, laboratory tasks, vital signs, medications, health concerns, assessment of plan of treatment, procedures, goals, clinical notes. Now, the cool thing about this is, again, they know they're just a lot of this, they're, they're going off of established, um, you know, establish things, uh, snowman and ICD 10 and, and other things that are, uh, readily available. So you're starting to see all these various things come together. Um, they're the, you know, they're, they're also planning for this data to be shared across fire, which is obvious.

Bill Russell: 21:13 And, um, you know, and, and actually I, uh, going a little long here, so I'll, I'll close this up, but one of the things that people like to say is, um, you know, they don't see where, uh, where it's really clearly defined what data blocking is and they define the need, but they don't really define it. I think this USCDI, it gives you, um, a pretty good picture of what data blocking is going to be. So they identify these datasets and eventually it will grow and, uh, it'll grow into payer information as well. And some other things as we sort of move forward. So this is gonna be the mechanism for identifying what data it needs to be shared, uh, for the 21st century cures act. Uh, which means that, uh, you know, your EHR providers are going to need to be able to share this or they will probably be subject to whatever governance is in place for this to say, hey, you're blocking data.

Bill Russell: 22:11 If you're not willing to share this data via fire to a qualified health information network, that will probably be considered data blocking. Um, all right, so I tried to end each one of these stories with, with a, so what, and I didn't really get to everything I wanted to talk about, but, uh, here's the, so what TIF get itself is, is moving pretty slowly, but it's something that should really be on your radar. Um, if you're large enough, you should probably assign somebody to it to monitor it and, uh, understand what's going on. Uh, if you have the, uh, resources, bring in a consultant to talk, I don't do this kind of consulting, so it's not it's self promotion, but bringing in a consultant to, uh, to talk to you about this so that you understand clearly how it resides and how you're going to coach and move your players to make sure that your health system is a compliant.

Bill Russell: 23:01 I think, uh, I think there's an awful lot of, uh, work that needs to be done at the EHR, uh, space. I think they're gonna fight it as evident, uh, by some of the comments that have been made recently. Uh, I think there's a lot of players that are gonna fight it, to be honest with you. Um, there's still a belief that, uh, the patients won't know what to do with the data, which I disagree with. I think once the data is out there, that there will be an ecosystem that arises that will help patients to understand what to do with the data. Uh, I think there's a, a, um, there's a belief that the data provides a competitive advantage. If I have the data, it's competitive advantage. It's not as easy for the patients to move around. And quite frankly, that's one of the things that the government's going after.

Bill Russell: 23:43 They, uh, you know, HIPAA is about portability and it's always sort of been about that as giving the consumers some choice, giving them the option to go where they need to get to, uh, in order to get the best care and to be able to understand and know what that best care is and who's, who's delivering it within your community. It also gives the, uh, CMS and other players the ability to identify a good providers versus a less than good providers and, uh, and there's a belief that you're going to be able to make a market. That's how one side thinks about it, to be honest with you. The other side thinks about it in terms of, uh, the ability for the government to really have more of a, uh, um, uh, let's, let's say a prescriptive method for making health care better. So if they're able to identify the players that are charging too much and whatnot, they can, uh, address those specific needs.

Bill Russell: 24:35 So it's interesting cause you have bipartisan support on addressing this, uh, maybe to two different ends, but it is what it is. And, uh, I, I don't know what the ends are and I'm not really promoting either end. I'm just essentially saying that, uh, the sharing of data, especially down to the patient is something that both parties really agree on. And, uh, we'll have to see how this plays out. So getting back to your, uh, health system, um, you know, stay ahead of this, understand the requirements, really get to know this. Uh, this, uh, uh, you, uh, USCDI, get to know it, understand it. You're already sharing this data today. Maybe not through fire, but likely through fire. You're already able to share it that way. Understand what your, uh, EHR capabilities are. Understand that some of this data may or may not be in your EHR and you may have to bring it in, uh, in another way.

Bill Russell: 25:31 Although it all looks from where I said most of it looks like it sits in your EHR. Um, and so understand where your EHR providers taking you, uh, how they're thinking about it and, uh, you know, what charges are available, what charges are you're going to incur as a result of this work. Um, do you need to be on a more standardized build? Uh, is there a certain upgrade you need to be a part of? So, um, lot of interesting stuff going on. I think it's a generally, I think it's good for the patient. I think it's good for communities, a represents some work for it and it represents costs for healthcare, um, healthcare it, so it's just something we have to plan for, something we have to be ahead of. So, uh, let's see. That's about it. That's about all we have time for, uh, this week.

Bill Russell: 26:17 So, uh, thanks for, uh, thanks for listening and really appreciate it and keep your comments coming bill@thisweekinhealthit.com. Uh, it's fantastic. I appreciate your feedback every Friday check-in, uh, for the interviews. Uh, I actually leave today for the, uh, health catalyst conference in Salt Lake City. Hope to have some videos for you from there and some good conversations, some great, uh, some great speakers. I'm really looking forward to that. This shows production of this week in health it for more great content. You can check out our website at this week health.com or the youtube channel at this week health.com/video actually, I'm not even sure that link works anymore. Just go to this week, health.com. Click on Youtube. You'll get there. Thanks for listening. That's all for now.