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TEFCA version 2 comments are due on June 17, 2019

May 8, 2019 | Author: HealthTech Solutions

For readers new to the Trusted Exchange Framework and Common Agreement (TEFCA), please see here and here. In this third installment, we discuss TEFCA version 2, how it differs from the previous effort, and what stakeholders may wish to consider as they develop comments.


Comments are due to the U.S. Department of Health and Human Services (HHS) Office of the National Coordinator (ONC) by June 17, 2019. Stakeholders may wish to consider TEFCA comments in light of their comments for the HHS proposed rules related to interoperability and patient access to data. Finally, the HIPAA Frequently Asked Questions released on April 19, 2019 are also relevant to this discussion. You can find our analysis here.  


ONC created a User’s Guide to TEFCA version 2, which is a very helpful overview, complete with specific examples. However, here are the six categories of important changes between TEFCA and TEFCA version 2:


Timelines extended

When a new version of the Common Agreement is published, entities that have signed on would have 18 months, instead of just 12 months, to implement updates.


Exchange purposes updated by adopting a subset of payment and health care operations purposes, as defined in HIPAA.

  • TEFCA’s exchange purposes included the following six domains: treatment, public health, benefits determinations, individual access, payment, and health care operations.
  • TEFCA version 2’s exchange purposes still included treatment, public health, benefits determinations, and individual access, but removed/modified payment and healthcare operations to instead comply with HIPAA by adding quality assessment and improvement; business planning and development; and utilization review. Those in italics only apply to HIPAA covered entities and business associates, which is all but benefits determinations and individual access.


Exchange modalities are updated by adding “push” notifications. QHIN broadcast (“bulk”) and targeted (“pull”) queries remain. Population-level data exchange was removed, as this technology is not yet mature enough to protect patients’ privacy in a network exchange such as this.  


The QHIN Prerequisites will be relaxed to allow more HINs to apply to be a QHIN.


The ONC will develop the Minimum Required Terms and Conditions (MRTC) for QHIN agreement, which will focus on trust issues within a large network. This document should set the conditions to improve data interoperability.


Previously, the details for a QHIN Technical Framework (QTF) were included in the TEFCA itself, but now it is a separate document that will be incorporated by reference in the Common Agreement.



  • TEFCA focuses on how QHINs must not exploit a pricing structure, enriching some QHINs and creating access barriers for others.
  • TEFCA version 2 states that QHINs cannot charge each other to exchange data when it is from a patient request (Individual Access Services). However, they may charge reasonable fees for Public Health and Benefits Determinations.
  • Other requirements around fees will be specified by the Recognized Coordinating Entity (RCE) and approved by the ONC.


In summary, there are now three documents on which the ONC seeks comment:

  1. TEFCA version 2
  2. Minimum Required Terms and Conditions (MRTCs)
  3. QHIN Technical Framework (QTF)


Comments are due on all three of these documents by June 17, 2019 and can be submitted at the bottom of this page.