Trust in data exchange relies on strong governance that ensures compliance and protection of individual’s information. At our February 13, 2025 Connecting for Better Health coalition meeting, Marilee Benson, President of Zen Healthcare IT, discussed new updates to the Trusted Exchange Framework and Common Agreement (TEFCA). In addition, C4BH provided state and federal policy updates related to data exchange.
TEFCA Special Session
As we step into 2025, the landscape of national health care data exchange is undergoing significant transformation amidst the federal administration transition and recent disputes of what types of data should be shared and accessed. This year is poised to be a transitional period for TEFCA and its influence on the national data exchange networks. TEFCA is a nationwide framework for health information sharing created by the U.S. Department of Health and Human Services Assistant Secretary for Technology Policy (ASTP). TEFCA aims to remove data sharing barriers for electronic health information among health care providers, patients, public health agencies, and payers.
The need for TEFCA alignment has been underscored by recent challenges, including a major dispute between two large national entities which raised concerns about the definition of “treatment” under HIPAA, reciprocity requirements for treatment, and how to diligently onboard new participants to TEFCA-based exchange. Simultaneously, Epic, a large electronic health record (EHR) vendor announced in 2024 that all of its customers will need to migrate to TEFCA-based exchange via their Qualified Health Information Network (QHIN) by the end of 2025, prompting a shift to TEFCA-mediated exchange.
TEFCA’s New Required Treatment Definition and Vetting Standard Operating Procedure
TEFCA recently introduced a more narrowly defined version of “treatment” that explicitly requires reciprocity, meaning that when queries are made under treatment, there is a required response obligation. This update is critical as it defines who can participate in TEFCA-driven exchanges and under what conditions.
In addition to the new definition of “treatment,” there is a new standardized vetting process for new TEFCA participants. The vetting process categorizes participants into three paths:
- Path 1: Designed for providers participating in Medicare or Medicaid. Since the government already validates their licensing, minimal additional evidence is required.
- Path 2: For providers who accept commercial insurance but not Medicare/Medicaid. Additional documentation, such as commercial insurance participation proof, is required.
- Path 3: For virtual providers and those without traditional insurance affiliations. These applicants must provide extensive documentation to prove licensure, covered entity status, and direct patient care involvement.
The new vetting Standard Operating Procedure simplifies participation for traditional providers while maintaining rigorous checks for non-traditional and virtual care providers. As TEFCA implementers work towards broader interoperability, these updates set the foundation for a more consistent and reliable health care data exchange system.
Implications in California
Amidst TEFCA governance developments, California health care and social services data exchange stakeholders face ongoing questions regarding TEFCA participation and policy alignment. During the conversation, participants shared the potential administrative burden faced by health information exchanges (HIEs) in implementing TEFCA. As Benson stressed, trust is critical as TEFCA evolves and iterates, and continued stakeholder dialogue on topics such as information blocking and dispute resolution will be essential for successful, widespread data exchange.
Federal and State Policy Updates
Following Benson’s presentation, Olivia Bundschuh, C4BH Policy and Program Manager, provided updates on federal and state policy developments including:
- Version 6 of United States Core Data for Interoperability (USCDI) is available for public comment through April 14 and proposes six new data elements. Access public comment here.
- The Center for Data Insights and Innovation (CDII) has finalized an amendment to the Data Elements to Be Exchanged Policy and Procedure (P&P), aligning the DxF with the USCDI version required by the ASTP Health IT Certification Program, beginning January 1, 2026.
In addition, Bundschuh gave an update of relevant California legislation bills that have been introduced thus far. The coalition will provide a final update on California legislative tracking after the February 21, 2025, deadline for all bill introductions.
