Sept. 17, 2021 – CommonWell Health Alliance submitted comments to the RCE on the QHIN Technical Framework Draft V1 as published July 28, 2021. We have always supported a fully connected nationwide ecosystem that links providers of all types and recognize we cannot do this alone. We support the goals and objectives of TEFCA and look forward to being one of, if not the first QHIN recognized in the country.
CommonWell Health Alliance is a not-for-profit trade association made of various health IT and health care stakeholders. As a membership-based trade association, we provide an environment to openly work on interoperability improvements across many cornerstones of health care including but not limited to technology companies, payers, State and Federal agencies, providers, clearing houses and patients. When the Alliance launched eight years ago, we started with services centered around Care Treatment and provided the ability for providers to query across other provider systems and retrieve data about a given patient. We have been and continue to be a patient-centered network available nationwide and are proud to have added Patient Access use cases to give individuals the ability to find and access their data through patient portals, personal health records and other patient-centric applications.
CommonWell has a simple vision: health data should be available to individuals and caregivers regardless of where care occurs. Additionally, access to this data must be built into health IT at a reasonable cost for use by a broad range of health care providers and the people they serve. At CommonWell, together with our service provider and members, we have created and deployed a vendor-neutral platform that breaks down the technological and process barriers that inhibit effective health data exchange. We leverage existing standards and policies in order to enable scalable, secure and reliable interoperability as easily as possible for our members and their customers across the nation. We are excited to see TEFCA is formed with a similar use of standards and think it has the potential to create the nationwide system we dreamed of through its interconnected system of Qualified HINs.
While we fully endorse the fundamentals of TEFCA and what the technical framework outlines in QTF Draft v1, we do have five specific areas for comment. The first three center around a potential challenge regarding the ability to build and maintain trust across the connected TEFCA system. Trusted is the first word in the acronym TEFCA; any potential for erosion of trust in the initial setup of TEFCA is a concern. The last two areas of comment center around focus – simply put, making sure we work towards creating a workable solution within the current timeline as outlined by the ONC without distraction. These five areas are detailed further in the submitted document.