The following is a guest article by Jay Nakashima, Executive Director at eHealth Exchange.
Key QHIN selection considerations for federal agencies and state and regional exchanges around control, innovation and flexibility
For the health IT community, 2022 has been a big year.
In January, the Trusted Exchange Framework and Common Agreement (TEFCA) became a reality, and in October applications opened for organizations seeking designation as Qualified Health Information Networks (QHINs). Already, several large networks – including mine – have signaled their intent to apply. And while it’s not clear when the first QHINs will be fully certified, it’s not too soon for potential participants to consider their options.
For federal agencies and state and regional exchanges, this is an excellent time to demonstrate leadership in interoperability by joining a network that will likely provide a ready on-ramp to TEFCA. By selecting a network that understands their unique needs, these entities can continue to serve their members and stakeholders – while gaining the broader access and connectivity that a large health information exchange (HIE) offers.
The Case for Federal Agencies
Currently, perhaps 99% of health data exchange is initiated to support treatment. For some federal agencies – the Defense Health Agency, Veterans Affairs, Indian Health Service and others whose missions focus on patient care – the case for joining a national exchange with intent to become a QHIN is fairly straightforward. A bigger network means more complete patient data to support care coordination, value-based care and population health management.
Other agencies, however, may not seek to join TEFCA until their primary reasons – or use cases – for participating in data exchange are supported. This list would include major healthcare payers like the Centers for Medicare & Medicaid Services and Tricare, public health agencies like the Centers for Disease Control and Prevention, and the Department of Education, which coordinates supportive health services for some student populations. The promise of these and other use cases was written into TEFCA with these agencies (and other entities with similar needs) in mind. As they seek to advocate for their priority use cases, these agencies would be well served by joining a large HIE that understands their needs, shares their concerns and welcomes their input.
The Case for State and Regional Exchanges
State and regional HIEs are critical to our nation’s goal of comprehensive interoperability. Often mandated by state law, these HIEs provide services for which TEFCA is not designed – including encounter notifications and analytics. Because they are uniquely able to connect rural providers, without them our healthcare system will not be able to extend the benefits of interoperable data sharing to all Americans. Furthermore, state and regional HIEs are optimally positioned to drive local innovation in service of their members and patients, including critical integrations between public health and social services.
To continue their important work, state and regional exchanges need to be able to function in accordance with state laws. By selecting a national HIE (and potential future QHIN) today that is structured and governed in a way that provides flexibility, state and regional exchanges can access the benefits of broad exchange. And, as they are ready, they can expand on those benefits while preserving the specific requirements of their states and members.
Key Questions That Differentiate Today’s Largest Exchanges
While all QHINs will be subject to a common set of baseline requirements, the QHIN Technical Framework allows for variations in governance and operation. As federal agencies and state and regional exchanges consider their next steps toward interoperability, I suggest they consider two important questions to identify a large HIE that will best meet their needs.
Does the Exchange Allow Participants Full Control Over Their Data?
Many exchanges store patient health data in long-term or permanent repositories. Of concern, some even store data on patients who haven’t been seen by their network members. Their reasons for doing so vary – to streamline transfer of patients between networks, for example, or to support research or other secondary uses of deidentified data. While long-term repositories certainly have some advantages, they can attract cyber criminals.
Under the eHealth Exchange model, participants retain full responsibility for and control over their patients’ data – including patient matching, cybersecurity, legal compliance and audit logging. We don’t store clinical data and only retain some demographic data for a limited time to support audits.
For federal agencies and state/regional exchanges that are subject to legally mandated security standards, any new cybersecurity threat must be carefully reviewed. A data storage model built for local autonomy virtually eliminates this concern, while allowing full participation in data exchange today and under TEFCA.
Agencies and state/regional exchanges should carefully examine all the ways their QHIN will use their data after it is exchanged for its original purpose.
Is the Exchange Designed for Inclusivity and Participation?
A few of the larger nationwide HIEs were created by vendors to serve the providers and health systems that use their technologies. Because agencies and state/regional exchanges serve constituents and members that use a variety of systems, they will need a QHIN designed for broad technological inclusivity.
As an outgrowth of the Office of the National Coordinator for Health Information Technology (ONC), eHealth Exchange was developed from the outset to be platform agnostic. We currently support more than 30 different electronic medical record technologies.
Equally important, our governing bodies include representatives from federal agencies, state exchanges, academic institutions, health systems, providers and provider collaboratives. We believe deeply in the importance of participatory and inclusive governance – particularly as new use cases for health data exchange are envisioned, prioritized and operationalized under TEFCA.
The Ultimate Deciding Factor
For the time being, participation in TEFCA is optional for all organizations. However, the expected advantages of QHINs – streamlined connectivity, reduced barriers to data access, expanded use cases – are significant. And if prior experience is any guide, regulatory agencies will eventually shift from incentives to requirements for participation.
As our nation marches steadily toward universal interoperability, every organization with a role in the U.S. healthcare system has ample reason to support the implementation of TEFCA. Whether that means joining a QHIN or becoming one, the force driving every decision we make should always be the best interests of the patients we serve.
About Jay Nakashima
Jay Nakashima is executive director of eHealth Exchange, the nation’s largest health information network connecting federal agencies, state and regional exchanges, and providers. A nonprofit, public-private entity, eHealth Exchange is dedicated to addressing the challenges of secure, health information exchange to improve patient care. For the past 13 years, eHealth Exchange has supported large-scale health information exchange across a network of diverse participants, including 64 regional and state HIEs using more than 30 different electronic medical record technologies.
