It's Tuesday News Day and today we go deep into TEFCA.
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Welcome to this week in Health IT News, where we look at as many stories as we can in 20 minutes or less that are gonna impact health it. It's Tuesday News Day, and here's what we have on tap. The ONC Awards, the Sequoia Project. As Tef FCAs recognized coordinating entity. You know, sometimes I, I pick a story and I realize I'm gonna just dig in.
'cause I, I wanna know more about Tef fca. I wanna understand where it's at, uh, 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, uh, a handful of stories on this. Uh, from the Impact Advisor site, teca, in a nutshell, nutshell, part two, um, took a look at the, uh, US core data for interoperability, uh, work that was going on, USF, uh, health online, uh, OONC and CMS, proposed rules, so forth and so on.
I read a bunch of government stuff this, uh, weekend and I thought I would, uh, . Share with you what I've learned around Tef fca. So this is gonna be the Tef FCA episode. Uh, I'll, 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 has set up podcasts 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.
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So let's get to the news. Uh, now before we get into Tef FCA 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 this show for any period of time. I'm really more of a patient mediated exchange kind of person. I believe that
Uh, that would be a better mechanism. It would be more, uh, viable, long run. I think it would be, uh, less intrusive, long run. I think there would be, uh, 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 deliver a much better solution.
With all that being said. I'm off my soapbox. We're gonna talk about Teka. Let's see, uh, where it's going. So here's, here's what's coming. Here's where Teka sort of 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.
And, uh, I'm not sure that's the case. It is moving slowly, but it's uh, 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 struggled 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, uh, 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 Tef fca, 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. Uh, April, uh, 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
Uh, Golder, uh, wrote a handful of these and just exceptional articles. You should check 'em out. Impact Advisor Site, they have a lot of good articles for this. This, this is really exceptional. Uh, April 19th, 2019, health and Human Services released. Its long awaited updated update to Teca. The proposed rule built on, uh, what HHS says earlier.
So, so what is it? Uh, we sort of talked about this. Teka 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, 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 Teka are 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, uh, 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've 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, 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 and Southern California and West Texas.
And, uh, at the end of the day, we did the research and realized that, uh, number of people from West Texas that ended up in one of our facilities in Southern California was so minuscule over the course of, uh, close to a 20 year period, uh, millions of patients. It was so minuscule. I mean, it was in the, it was less than a hundred that had made that, uh,
That trek. And so from a business case standpoint, did it really make sense for me as 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, on and they have on the podcast or are making the case on, um, Kaiser, you know, doesn't really share information really effectively between Maryland and Southern California.
Um, and again, the case is, you know, if, 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 so that they can start to innovate around the patient experience around the patient.
Well, the power for brokers and stakeholders that really don't want Silicon Valley to innovate. Quote unquote. Um, and we can argue that, and we can go back and forth, but the powerful, uh, are, are the EHR providers. It's the, uh, it's quite frankly, it's everybody. It's everybody who has an established business.
And we're not talking about small businesses here. We're talking about billions, uh, you know, billions of dollars in, in businesses. The, uh, the providers don't really have a, a. An incentive to, uh, to share the data, uh, 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, um, the cost of running it within healthcare today, am I going to, you know, rise this up to the level of say, creating, uh, new consumer experiences?
Probably not. To be honest with you. So I'm not gonna be spending that kind of money. There's a lot of, of me, let me get back to the, the teca at this point. So they're trying to, they're trying to share data share across a broader spectrum. Um, and again, to close out that case, my case is that if the data was available to, uh, 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, they get access and second of all, it costs more money. For the solutions that they're developing. And, you know, TEF, FCA and OMC, 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. Uh, and they also wanna 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 and say, Hey, let's start sharing data anyway. Let's take a look at, so exchange purposes have been updated and this was, uh, uh, this article is probably in June or, or something to that effect.
So HHS is defined and broaden a specific subset of payment and healthcare operation purposes for teca. Um, and that is treatment benefits, determination, quality assessment and improvement, business planning and development, public health utilization review. And individual access services. So, TEF fca, 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 gonna have the qualify, uh, what do they call it, the qualifying entity. What was Sequoia? Was name the . Uh, recognize 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.
So the, uh, qualified health information networks are going to, uh, . Have a handful of ways that they're sharing data. They're gonna share data, uh, they're gonna do broadcast query, targeted queries, message delivery, or a push. So, well, here's what they look like. Request for a patient's EHI from all, uh, QS. Uh.
That's the broadcast targeted query is request patient's EHI from a specific QHIN and then a push is QHIN delivery of a patient's EHI to one or more specific QHIN. So they're starting to, you're starting to see this, uh, materialize in terms of how they're, uh. How they're going to govern it, how they're going 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. Alright, so there's, they're starting to put together the security requirements for exchange. This is one of the major pushbacks of, uh, TEF FCA 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 not giving us, uh uh, you're not telling us how it's gonna be protected. Well, um, you know, they have, uh. They have a handful of things and a lot of specifications. I'm not gonna go into 'em. They're using nist, they're using, oh gosh, they're using a bunch of different specifications that are, have been used in the federal government in other areas.
Uh, identity proofing, user authentication, breach notification, uh, EHI disclosure outside of the US meaningful choice, uh, security labels and so forth. So they have to defined a set of security requirements. There's still more, I think, more work to be done in this area. But, um, but they are defining the, uh, 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 Teka per se, but, uh, if, if you are a provider. But there is, uh, 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 gonna 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.
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 Sequoia 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, 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. Trusted exchange framework. So, uh, standardization, transparency, cooperation and non-discrimination, uh, privacy, security and safety access population level data so that the Trusted Exchange framework establishes, uh, again, based on the 21st Century Cures Act.
Uh, represents a set of six common principles serving as rules of the road for information exchanges that are designed to facilitate trust among the, uh, hi. And by the way, your HIE today, your, your regional HIEs and 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, uh, funding and money associated with it and some may not. Um, I'm not sure why they wouldn't, but, uh, some may not for, uh, 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, uh, a dump of what I, uh, went through this weekend and, um, . Podcast I listen to and things I, I've, I've gone tried, just tried 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, uh, conversation.
So, standardization, transparency, cooperation, and non-discrimination, privacy, security and safety, access and population, uh, level data. So those are the, uh, six common principles for the trusted exchange framework. Now, that's taf. The KA is common agreement. The common agreement establishes a governance necessary to scale TEF fca.
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 to scale the proposed system of connected ins 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 gonna, I'm gonna pick up the pace a little bit here. Got about five minutes to go, so, . The recognized qualifying, uh, coordinating entity.
So this is important now because now it's been, uh, is, is, uh, now it's been awarded. So the RC e's third leg of the Tef Teca stool and will establish a public private partnership for HHS in that it will private, it will be privately owned entity, competitively selected by HHS and administer. Uh, TEF fca. So the RCE will administer TEF FCA and we'll have responsibility for virtually all of the key components of poor administration and implementation of Tef Tef fca, including develop and update and implement and maintain the common agreement.
Identify designated and monitor, uh, qualified health information networks. Modify, uh, and update the information network technical framework. Uh, virtually, uh, convene public listening sessions. Develop and maintain the process of adjudicating, uh. Qualified network compliance and proposed strategic, uh, strategy to sustain the common agreement at a national level after the initial cooperative agreement period.
So, uh, those are some of the things that the Sequoia Project is going to be doing. So, uh, 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. Sequoia's been, uh, adopted, you know, what are some of the next things that are gonna 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. It won't be specified until. The spring of 2020, if everything goes well, there's a lot of people to, uh, a lot of, uh, there's a lot of entities to bring together, to have conversations.
Uh, you have to worry about, um, not doing anything that's gonna disrupt the current, uh, sharing . Uh, uh, mechanisms that are already in place 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 wanna get buy-in, you wanna 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, uh, US court data for interoperability. Uh, USD. Uh, I'm sorry, U-S-C-D-I. So, uh, what is the U-S-C-D-I? This U-S-C-D-I 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, interop, interoperable, uh, this is from, uh, 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. Uh, but the latter, each of these has issues surrounding it, but the latter is an area that the ONC for health, it is seeking consensus on in order to create standardized datasets that all electronic health records will contain.
The U-S-C-D-I 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 and 2020. In other words, the US CDI i's goal is to establish what information . All electronic health record systems should be able to share no matter where you are in the United States, and no matter what differences exist between the systems and services providers, uh, of any given health facility.
The U-S-C-D-I 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 incorporate stakeholder feedback and some of our listeners. Are on that task force, and we're gonna have a guest, uh, in the not too distant future who's also on that task force.
So, um, you know, and, 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, uh, 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, uh, shared.
And it's, you know, it's, it's pretty standard stuff. If you set up a, uh, clinically integrated network, it's standard stuff, you're, you're gonna see, uh, demographics, . Um, some, uh, let's see. Wow, that's small. Let's see. 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
Oh 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.
Uh, 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, um, laboratory tests, vital signs, medications, health concerns, assessment of plan of treatment, procedures, goals, clinical notes. Uh, now the cool thing about this is again, they, you know, they're, they're just a lot of this, they're, they're going off of established.
Um, you know, established things, uh, nommed 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, the, you know, they're, they're also planning for this data to be shared across fire, which is obvious. And, um, you know, and, and actually, I.
uh, going a little along 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, uh, they define the need, but they don't really define it. I think this U-S-C-D-I gives you, um, a pretty good picture of what data blocking is going to be.
So they identify these data sets and eventually they, 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 BA for the 21st Century Cures Act. Uh, which means that, uh, you know, your EHR providers are gonna 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. If you're not willing to share this data via fire to a, uh, qualified health information network, that will probably be considered data blocking. Um, alright, so I, I try 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 Teka 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, uh, consultant to talk. I, I don't do this kind of consulting, so it's not a self-promotion, but bring in a consultant to, uh, to talk to you about this so that you understand clearly, uh, how it resides and how you're going to coach.
And move your players to make sure that your health system is, uh, compliant. 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, uh, patients won't know what to do with the data, which I disagree with. I think once the, uh, 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, uh, um, there's a belief that the data
Provides a, uh, competitive advantage. Uh, if I have the data, it's a 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. They, uh, you know, HIPAA is about portability and it, it's always sort of been about that, is 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, uh, within your community.
It also gives the, uh. CMS and other players, the ability to identify, uh, good providers versus, uh, less than good providers. And, uh, and there's a belief that you're gonna 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 healthcare better. So if they're able to identify the players that are charging too much and whatnot, they can, uh, address those specific needs. So it's interesting 'cause you have bipartisan support on addressing this, uh, maybe to two different ends, , but it, 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, uh, especially down to the patient is something that, uh, 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, u um, US CDI 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. Although it all looks from where I sit, most of it looks like it sits in your EHR. Um, and so understand where your EHR provider's taking you, uh, how they're thinking about it, and, uh, you know, what charges are available, what charges are going, you're going to incur as a result of this work.
Um, do you need to be on a, uh, more standardized build? Uh, is there a certain upgrade you need to be a part of? So, um, . A lot of interesting stuff going on. I think it's, uh, generally I think it's good for the patient. I think it's good for communities. It represents some work for it. It represents cost for healthcare, um, healthcare it.
So just something, uh, 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. So, uh, thanks for, uh, thanks for listening. I really appreciate it. Keep your comments coming, bill at this week in health it.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, uh, videos for you from there. and, uh, 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.