WASHINGTON, June 19, 2019 (GLOBE NEWSWIRE) -- DirectTrust has filed a comment letter with the Office of the National Coordinator for Health Information Technology (ONC) on the second draft of the Trusted Exchange Framework and Common Agreement (TEFCA). DirectTrust is a non-profit healthcare industry alliance created to support secure, identity-verified electronic exchanges of protected health information (PHI) between provider organizations, and between providers and patients, for the purpose of improved coordination of care.
The DirectTrust response urges ONC to build on what is already working in the health information exchange marketplace and to adopt a “lightweight” approach directed at establishing the minimum conditions for efficient trusted exchange to occur.
“While we applaud the goals of TEFCA Draft 2 to advance nationwide healthcare interoperability between existing networks, we advocate for a more agile and iterative approach, which would, appropriately, tie back to the goals of Congress in the 21st Century Cures Act, which includes ensuring that electronic health information will follow the patient for the most fundamental purposes—individual treatment and access—that all stakeholders can agree on,” stated DirectTrust President and CEO Scott Stuewe.
Specifically, DirectTrust proposes that ONC allow and encourage existing frameworks to operate cooperatively to create a Common Agreement focused on the minimum conditions for efficient trusted exchange. Alternatively, DirectTrust suggests ONC permit and encourage the RCE to create more formal coalitions of these same players to achieve the same goals without limiting or prescribing what roles such stakeholders are permitted to play. “Either of these approaches could enhance ONC’s goals for TEFCA and best avail it of our collective assets without fundamentally disrupting the market for healthcare exchange,” Stuewe continued in the comment letter.
“Why reinvent the wheel? We strongly urge ONC to build on what’s working, rather than creating an entirely new construct with significant complexities and the potential for increased costs. Simplified exchange mechanisms are now functional. Layering a QHIN-Participant-Participant Member structure onto this functionality adds complexity and potential cost with little added benefit; a multi-layered structure risks disordering services that are already working well for providers and patients,” stated Stuewe.
Referring specifically to the role of DirectTrust, Stuewe wrote, “Both TEFCA Draft 2 and the draft QHIN Technical framework fail to leverage the considerable investments made by government and the industry in the DirectTrust network. Direct messaging and the players that enable it are an extremely valuable asset that has been ignored by TEF, which favors instead, a push messaging replacement utilizing a different topology and a lesser-used standard. This is a missed opportunity of tremendous proportion as the DirectTrust nationwide network has already achieved the top-level goals of both the 21st Century Cures Act and the TEF, and could be leveraged to accelerate progress on innovative used-cases not yet fully addressed by alternative mechanisms. We strongly advocate for TEFCA and the final QHIN Technical framework to be consistent with the approach in the 21st Century Cures Act’s proposed rule with regard to support for all current interoperability elements and for FHIR.”
In conclusion, Stuewe shared DirectTrust’s view that “TEFCA’s goals will be best served by a more agile, incremental approach implemented through pilot testing with full transparency and stakeholder input.”
The DirectTrust response to TEFCA Draft 2 includes nine specific comments and recommendations, including:
Modify the definition of a QHIN in TEF to allow broader participation
ONC should explicitly encourage the use of DirectTrust and other successful trust networks already in place and operating at scale, rather than stand up an inconsistent alternative for push messaging within the QHINs...The TEF structure must be flexible enough to support and/or interoperate with existing exchange frameworks…ONC should leave the precise role and obligations of the QHIN to the RCE in collaboration with all stakeholders and remove it from TEF.
Ensure the RCE will collaborate with stakeholders through appropriate oversight
ONC should establish an adequate oversight and public input process that is transparent and fair to all impacted stakeholders.
Promote the use of Secure Direct Messaging in public health
Rather than offer an alternative mechanism for push messaging to serve the public health sector, ONC and the RCE should collaborate with the Direct messaging community to make the most of current capabilities in the market to connect public health and payers.
Recognize the importance of governance and a technical trust framework for FHIR
ONC and/or the RCE should collaborate with DirectTrust and the Direct community to adapt the DirectTrust model for use with the FHIR ecosystem as a component of a more complete fabric for health information exchange.
Leverage identity proofing at existing networks and adopt standard certificate policies
To realize TEFCA’s goals, ONC should encourage the RCE to collaborate with organizations working to identity proof the healthcare ecosystem at scale. This can provide a foundation for scalable trust that allows individuals and organizations to “proof” once and leverage this proof for multiple purposes.
Disallow TEFCA provision of a safe harbor without changes
TEFCA Draft 2 is not an adequate safe harbor for compliance with the 21st Century Cures Act’s legal prohibition against information blocking…Instead of a TEFCA-based safe harbor, DirectTrust advocates that ONC incentivize health IT developers to demonstrate interoperability with real-world testing to demonstrate that appropriate users can locate and operate workflows like Direct messaging.
The complete DirectTrust response may be viewed here.
About DirectTrust
DirectTrust™ is a non-profit, vendor-neutral alliance initially created by and for participants in the Direct community, including Health Information Service Providers (HISPs), Certificate Authorities (CAs), Registration Authorities (RAs), doctors, consumers/patients, and vendors. DirectTrust serves as a forum, governance, and accreditation body for persons and entities engaged in exchange utilizing the Direct Standard™, supported by DirectTrust’s robust security and trust framework. The goal of DirectTrust is to develop, promote, and, as necessary, help enforce the rules and best practices necessary to maintain security and trust within the Direct Secure Messaging community. DirectTrust is committed to fostering widespread public confidence in the interoperable exchange of health information. To learn more, visit www.directtrust.org.
Contact
Ed Emerman
Eagle Public Relations
609.275.5162
eemerman@eaglepr.com