On June 17, 2019, AHIP submitted comments in response to Draft 2 of the Department of Health and Human Services’ (HHS) Office of the National Coordinator for Health Information Technology’s (ONC) Trusted Exchange Framework and Common Agreement (TEFCA), a common set of principles intended to facilitate the trusted exchange of electronic health information.
AHIP expresses support for ONC’s overarching principles for trusted exchange and establishment of a network-of-networks policy framework for trusted exchange of health information. However, we note significant concerns that the TEFCA’s proposals fail to recognize both the operational complexity associated with building the required technology and the lack of mature standards for the proposed data elements and exchange. Our letter outlines a series of recommendations to address our concerns.