Common Agreement for Nationwide Health Information Interoperability

Common Agreement

The 21st Century Cures Act, passed in 2016, calls for the development of a trusted exchange framework and a common agreement. The Trusted Exchange Framework is a set of non-binding but foundational principles for health information exchange, and the Common Agreement is a contract that advances those principles. The Common Agreement establishes the technical infrastructure model and governing approach for different health information networks and their users to securely share clinical information with each other – all under commonly agreed-to rules-of-the-road. The Common Agreement supports multiple exchange purposes critical to improving health care and has the potential to benefit a wide variety of health care entities. This flexible structure allows stakeholders—such as health information networks, ambulatory practices, hospitals, health centers, federal government agencies, public health agencies, and payers—to benefit from TEFCA through improved access to health information. Individuals also benefit from TEFCA and seek access to their health information through entities that offer individual access services.


Importance of Common Agreement V2

 

Common Agreement V2 adds a number of new elements to significantly advance nationwide network-to-network interoperability. The biggest change is the adoption of Fast Healthcare Interoperability Resources (FHIR®) -based exchange, which will allow participants to leverage TEFCA governance, policy, and technical services to scale FHIR Application Programming Interface (API)-based exchange nationwide. In addition, SOPs  released today introduce policies and processes to further enhance the trust model that is the central feature of TEFCA. These SOPs include policies for:

  • Transitioning TEFCA governance to the permanent TEFCA Governing Council comprising QHINs and Participants;
  • Requiring cooperation by QHINs, Participants, and Subparticipants in investigating and responding to concerns raised by TEFCA leadership, QHINs, or Participants/Subparticipants about matters related to exchange under TEFCA;
  • Reporting TEFCA security incidents to the RCE and potentially impacted QHINs, Participants, and Subparticipants;
  • Specifying requirements on Individual Access Service providers for protection of privacy and security of individually identifiable information, consent from individuals about uses of their information by the IAS provider, and reporting to individuals about security
    incidents involving their information;
  • Clarifying when Treatment exchange requests require response, when requests come from, among others, hospitals, ambulatory physician offices, LTPAC, pharmacies, laboratories, and individuals licensed to provide health care such as psychologists, nurses, social workers, and physical/occupational therapists;
  • Catalyzing scalability of FHIR API-based exchange by supporting Facilitated FHIR transactions for providers, payers, public health, individual access, and other authorized uses, including publication of FHIR endpoints in the TEFCA Directory;
  • Advancing individual access by enabling use of FHIR OAuth 2.0 capabilities that helps providers and payers meet HIPAA compliance requirements and more fully support individual access through TEFCA; and
  • Allowing Participants, including care providers, payers, and public health authorities, to authorize contracted Delegates to conduct TEFCA transactions on their behalf.

 

Together, these policy and technical documents, which were developed and updated through collaboration between ONC, the RCE and the TEFCA community following established governance processes, advance TEFCA FHIR-based exchange and clarify expectations and requirements for TEFCA exchange under Common Agreement V2. We have also re-published an updated TEFCA Glossary, as well as the updated TEFCA
Cross Reference Resource
that identifies which Common Agreement and/or Participant/Subparticipant Terms of Participation section(s) each SOP references.  

Key Concepts that have Evolved: Version 1.1 to Version 2.0

Common Agreement and QTF Version 1.1 Proposed Common Agreement and QTF Version 2.0
Fundamental requirements and components of TEFCA mostly included within Common Agreement and QTF Version 1.1 More details moved to SOPs
Model Participant/Subparticipant flow-down terms Static Participant/Subparticipant Terms of Participation
Exchange only occurs QHIN-to-QHIN via IHE protocols Facilitated FHIR available between Participants/Subparticipants
Exchange within QHINs not considered TEFCA exchange TEFCA Exchange identified by unique TEFCA code
Six (6) authorized Exchange Purposes (XPs) Six (6) authorized Exchange Purposes (XPs) with new sub exchange purposes and implementation guidance
Two (2) XPs require a response: Treatment and Individual Access Services (IAS) Three (3) XPs require a response: Treatment, IAS, and Health Care Operations SubXP-1 (FHIR only)
All QHINs, Participants, and Subparticipants must respond Introduction of Principal/Delegate roles and requirements
Participants and Subparticipants may not participate with more than one QHIN Participants and Subparticipants may conduct TEFCA Exchange in multiple QHINs using multiple Nodes
Privacy/security obligations apply to all  Privacy/security obligations apply to all 

Common Agreement for Nationwide Health Information Interoperability

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