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New TEFCA Procedure to Facilitate Enhanced Exchange of Public Health Data

September 10, 2024

Overview

The availability of timely and accurate data is the lifeblood of modern public health practice and key to advancing health equity for all. The federal Trusted Exchange Framework and Common Agreement (TEFCA) took another step forward on August 6, 2024, with the release of five new or updated standard operating procedures which hold the potential to enhance exchange of timely, accurate data, in a usable format, across Qualified Health Information Networks nationwide.

The availability of timely and accurate data is the lifeblood of modern public health practice and key to advancing health equity for all. Data can identify communities hardest hit by public health threats and helps focus public health resources for maximum effectiveness. The Trusted Exchange Framework and Common Agreement (TEFCA)—a major federal initiative to improve the exchange of health data for permitted purposes nationwide—took another step forward on August 6, 2024, with the release of five new or updated standard operating procedures (SOPs). Of particular interest is the much-anticipated Public Health Exchange Purpose (XP) Implementation SOP which will facilitate better connections between providers and public health data systems. This article provides a high-level overview of TEFCA data exchange, explores the new Public Health XP Implementation SOP, and discusses its significance for state, Tribal, local and territorial health department data exchange.

What is TEFCA?

The 21st Century Cures Act directed the National Coordinator for Health Information Technology to develop or support a trusted exchange framework, including a common agreement between health information networks (HINs) across the country—all with a view to significantly improving exchange of health data based on common interoperability standards. The resulting exchange framework and Common Agreement, known collectively as TEFCA, has three main goals: to establish a governance, policy, and technical framework for interoperability across the country; to simplify connectivity to securely exchange data; and to empower individuals to gather their own health information. TEFCA currently supports data exchange for the following defined purposes (referred to as “Exchange Purposes” or “XPs”): treatment, payment, health care operations, public health, government benefits determination, and individual access services.

How does TEFCA facilitate nationwide data exchange?

At the heart of TEFCA data exchange lies a group of Qualified Health Information Networks (QHINs). These are health information networks (HINs) that have met certain eligibility criteria and technical capacity requirements, have been onboarded, and are parties to the Common Agreement. Any organization that meets the eligibility criteria may potentially become a QHIN. QHINs connect directly to each other to facilitate nationwide interoperability. Each QHIN also connects participants, such as public health authorities (PHAs), hospitals, health systems, and labs, to exchange data through the QHIN. These participants may in turn connect subparticipants, such as individual medical practices and community health centers, which do not connect directly with QHINs but may connect with participants to exchange data.

What are TEFCA SOPs?

TEFCA Standard Operating Procedures are written procedures that provide detailed information relating to TEFCA data exchange. They determine the governance and technical requirements for particular types of data exchange, which vary according to the different purposes allowed under TEFCA.

What is the purpose of the Public Health XP Implementation SOP?

The Public Health XP Implementation SOP lists requirements that QHINs, participants and subparticipants must adhere to when exchanging data under the Public Health XP and includes specific provisions for electronic case reporting (ECR) and electronic lab reporting (ELR) use cases.

What is in the Public Health XP Implementation SOP?

The v1.0 Public Health XP Implementation SOP establishes eligibility and technical requirements for public health exchange through TEFCA generally, as well as for ECR and ELR use cases specifically.

A TEFCA query is the act of asking for information through the TEFCA exchange. While eligible PHAs may initiate queries for data for any allowable public health purpose (“Level 1” public health purpose queries), they may also choose to define their queries under the narrower ECR or ELR sub-purposes (defined as “Level 2” public health queries). Only PHAs or their delegates may conduct QHIN Queries or Fast Healthcare Interoperability Resources (FHIR) Queries under either level 1 or level 2 public health exchange.  Currently, health care providers are not required to respond to public health queries.

Health care providers may reciprocally query PHAs under a separate exchange purpose—the Treatment XP. However, the SOP states that PHAs are “encouraged, but not required to respond to queries from TEFCA connected entities.”

Finally, the SOP also notes that future iterations of the SOP may include new use cases to address additional public health priorities.

Why is the Public Health XP Implementation SOP significant?

Data exchange is essential to providing equitable care and improving public health for all communities. The Public Health XP Implementation SOP holds the potential to enhance exchange of timely, accurate data, in a usable format, across QHINs nationwide. Electronic case reporting and ELR, in particular, are essential tools in exchanging data for public health surveillance and identifying disease outbreaks. This SOP focuses on, and advances, both of these use cases, in addition to Public Health XP. What’s more, TEFCA’s focus on nationwide interoperability and standardization, and the requirements laid out in this SOP, are steps toward connecting previously siloed public health systems. FHIR exchange under TEFCA will make ECR even more seamless. Overall, this SOP provides standards and implementation guidance that help move the needle toward a modernized public health data infrastructure.

This post was written by Stephen Murphy, Acting Director, Mid States Region, Network for Public Health Law. 

The Network for Public Health Law provides information and technical assistance on issues related to public health. The Network for Public Health Law promotes public health through non-partisan educational resources and technical assistance. This document is provided for informational purposes only and does not constitute legal advice or legal representation. Neither provision of this document nor any communications with the Network for Public Health Law and its staff create an attorney-client relationship. For legal advice, please contact your attorney.

Support for the Network is provided by the Robert Wood Johnson Foundation (RWJF). The views expressed in this post do not represent the views of (and should not be attributed to) RWJF.