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If you are looking for current progress and updates for TEFCA, please visit the dedicated ONC TEFCA RCE website. Below are responses to the prior draft Trusted Exchange Framework as The Sequoia Project, and not in the role of the ONC TEFCA RCE.
In this letter, we provide priority high-level and detailed comments intended to help ONC further refine the second draft of the TEFCA. We share an overall aim to improve the health and health care of patients and our nation through more seamless and secure patient, provider and other appropriate stakeholder access to and use of health information.
In April 2019, ONC published the Trusted Exchange Framework (TEF) Draft 2 for public comment. This updated, second draft TEF package was developed by ONC with input from all of the public comments on the TEF Draft 1 and includes three components: (1) the TEF Draft 2; (2) the Minimum Required Terms and Conditions (MRTCs) Draft 2; and (3) the Qualified Health Information Network (QHIN) Technical Framework (QTF) Draft 1.
The Sequoia Project staff and Board of Directors have carefully reviewed the TEFCA Draft 2 and prepared our response.
Below are the final comments submitted to ONC on June 13, 2019.
The Sequoia Project’s response to ONC TEF Draft 2 (PDF) includes:
We urge ONC to be very mindful of the congressional intent that the TEFCA avoid disruption and duplication of “existing exchanges between participants of health information networks”. In our view, as currently drafted, the TEFCA would both disrupt and duplicate existing exchange mechanisms and would require extensive changes to existing activities and revisions to the terms of thousands of legal agreements. We urge ONC to look for every opportunity to minimize or eliminate such duplication and disruption, especially in the need to revise legal agreements that have, in many cases, taken years to be developed and executed in support of large-scale information sharing.
In January 2018, ONC published a Draft Trusted Exchange Framework (TEF) for public comment. The Draft TEF is meant to build on and recognize the significant work done by the industry over the last few years to broaden the exchange of data to meet the needs of patients and the providers who serve them. It aims to ease the flow of information between healthcare stakeholders and expand patient access to their health data, while allowing for a competitive marketplace that fosters innovation and development of new technologies to improve care coordination, population health management, and patient outcomes.
The Sequoia Project staff and Board of Directors have carefully reviewed the TEFCA and prepared our response.
Below are the final comments submitted to ONC on February 16, 2018.
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