June 17, 2019 – CommonWell Health Alliance submitted comments to the Office of National Coordinator (ONC) at the Department of Health and Human Services regarding the Trusted Exchange Framework and Common Agreement (TEFCA), published on April 19, 2019.
CommonWell is very supportive of the goals and direction articulated by TEFCA. We agree that a single on-ramp will increase access to data across the US. In line with the mission of the Alliance, we are optimistic about the potential for TEFCA to increase the level of empowerment by individuals and their care providers by enabling them to get the data they need to make the best care decisions.
At the center of our support is the notion, formalized in our own vision and emulated by TEFCA, that person-centered data exchange should be the minimum standard for nationwide interoperability, allowing a person’s information to be found and retrieved with no “blind spots”.
The architectural concept espoused by TEFCA, calling on a federated query model, builds on the approach that the Alliance has successfully delivered to the market nationwide. CommonWell Members already know the benefit of moving away from the world where they have to support – legally, organizationally and technically – thousands of point-to-point interfaces. Their participation in the CommonWell network underscores their commitment to that idea.
CommonWell Health Alliance intends to become a Qualified Health Information Network (QHIN), subject to reasonable improvements that we expect will be incorporated into the final Framework. In addition, CommonWell intends to play an active role in the finalization of the Recognized Coordinating Entity (RCE) and would expect to participate as an active stakeholder in the evolution and governance of the RCE.