Sequoia Project Announced as TEFCA’s Recognized Coordinating Entity

Yesterday (September 3, 2019) ONC announced that it has awarded the Sequoia Project the cooperative agreement to serve as the Recognized Coordinating Entity (RCE) for TEFCA (the Trusted Exchange Framework and Common Agreement).

What is the RCE and why is it important?

The RCE is the cornerstone of TEFCA, as it will be directly responsible for the Common Agreement (the “CA” of TEFCA). Essentially, now that the Sequoia Project has been identified as the RCE, the implementation timelines of TEFCA will accelerate.

The RCE will have the responsibility to:

• Develop, update, implement and maintain the Common Agreement.
• Identify, designate and monitor QHINs.
• Modify and update the QHIN Technical Framework.
• Virtually convene public listening sessions.
• Develop and maintain a process for adjudicating QHIN noncompliance.
• Propose strategies to sustain the Common Agreement at a national level after the initial cooperative agreement period.

In other words, virtually all of the key components for administration and implementation of TEFCA are the responsibility of the RCE.

What is the Common Agreement?

The Common Agreement establishes the governance necessary to implement TEFCA, and will now be the responsibility of the Sequoia Project. The components of the Common Agreement will include:

Minimum Required Terms & Conditions (MRTCs)

• Establish the mandatory minimum required terms and conditions with which Qualified Health Information Networks (QHINs) may voluntarily agree to comply.
• Designed to help remedy weaknesses inherent to existing trust agreements that are perceived to impede nationwide interoperability.

Additional Required Terms & Conditions (ARTCs)

• Facilitate the day-to-day operation of an HIE.
• Potentially could include items such as fee schedules, QHIN application and onboarding, including processes for suspending and termination of noncompliant QHINs, etc.

QHIN Technical Framework (QTF)

• Describes the functional and technical requirements that a Health Information Network needs to fulfill in order to function as a QHIN under the Common Agreement.
• The QTF describes in detail the functions to be included by a QHIN, the technical details supporting those functions and exchanges, and the types of queries to be supported.

Timelines: What’s Next?

Originally targeted for “mid-2018,” this long-overdue appointment of the RCE is a welcome announcement for TEFCA advocates, as it is a prerequisite for development of the Common Agreement and the overall implementation of TEFCA.

ONC is targeting the first draft of the Common Agreement for “spring 2020” (quite a delay from the original 2018 target specified in the 21st Century Cures Act), and then it will have to be finalized. Applications and acceptances of QHINs will then follow, and once appointed, QHINs will then have 18 months to implement. Adding all this up (along with a few assumptions) puts TEFCA availability sometime in 2022:

Speculative Timeline

(click on image for larger view)

Draft 1 of the Common Agreement

Certainly the Common Agreement is the key next step for TEFCA, with the first draft, again, due in “spring 2020.” Development of the Common Agreement will be a tall order for Sequoia to deliver in essentially nine months (give or take), yet it will be a critical step in the advancement of TEFCA. Prospective QHINs will need to fully understand the requirements and terms of their potential involvement — the “rules of the TEFCA road” — which the Common Agreement will be providing.

Yet spring 2020 is only the target for the first draft agreement. It’s still unclear how ONC plans for this to be finalized, although one would expect at least one comment period prior to a final Common Agreement. How this all will affect the overall TEFCA timeline remains to be seen. Regardless, this announcement is welcome news, and we’ll be watching (somewhat impatiently) as Sequoia begins development of the Common Agreement and establishes its role as the RCE for TEFCA.

For more information on TEFCA and the RCE, please check out our earlier blog posts:

TEFCA in a Nutshell

TEFCA in a Nutshell – Part 2