Earlier this week, industry stakeholders got a key health IT policy question of theirs answered when the Office of the National Coordinator for Health IT (ONC) named The Sequoia Project as the organization that will be the Recognized Coordinating Entity (RCE), and which will manage and oversee Qualified Health Information Networks (QHINs) under the Office of the National Coordinator for Health IT's Trusted Exchange Framework and Common Agreement (TEFCA).
For months, as health IT observers anxiously awaited the release of TEFCA’s second draft, which was finally released in June, rumors about which group would make for the right choice to serve as RCE concurrently began to ramp up. Part of the second draft’s release included a $900,000 funding announcement for a nonprofit RCE in year one, with funding in additional years contingent upon availability of funds and satisfactory completion of milestones.
In the eyes of many, The Sequoia Project—originated in 2012 to advance healthcare interoperability, and which has managed the eHealth Exchange, which has become the largest health information network in the U.S., as well as supporting the Carequality initiative—felt like a natural fit. “Sequoia seemed to be the consensus likely choice, so this wasn’t a surprise. Most are eager to see what’s next and how this will advance interoperability,” says Dan Golder, principal at the Illinois-based consulting firm Impact Advisors.
A core responsibility for the RCE will be to develop a Common Agreement that includes the Minimum Required Terms & Conditions Draft 2 and Additional Required Terms & Conditions developed by the RCE (ARTCs) and approved by ONC. The Common Agreement will be published on HealthIT.gov and in the Federal Register. It will then have to identify and monitor QHINs that voluntarily agree to sign and adopt the Common Agreement.
Golder believes that the development of the Common Agreement is the key next step, and greatest challenge, particularly with the targeted timeline for the first draft Common Agreement to be available this coming spring, further noting that it may be 2022 or later—pending possible delays—before TEFCA will be operational.
Following ONC’s RCE announcement this week, Healthcare Innovation Managing Editor spoke with Mariann Yeager, CEO of The Sequoia Project, about her reaction to the news, how quickly the entity will move forward with its TEFCA-related work, what some of its core goals are right away, and more. Below are excerpts of that discussion.
Were you surprised that The Sequoia Project was awarded this opportunity, or were you expecting it?
We were delighted. We learned a long time ago not to expect [things], but we were hopeful and confident in the proposal that we submitted and the support we had for it. We didn’t expect it but we are honored. It’s an important role and important work.
What was the process of applying like?
It was an intensive planning process. [ONC] basically laid out the expectations for what the RCE would be expected to do in the Notice for Funding Opportunity, which was publicly available. That part was clear cut. From our perspective, we looked at the aggressive timeframe and then drew from our extended experience as we have [performed] similar activities in developing and supporting trust agreements, getting stakeholder buy-in, and supporting that in a way that engenders public good. We spent a lot of time thinking about how to practically accomplish the goals, and fulfill the deliverables in a timeframe that we think is rather expedient.
Will Sequoia hire someone specifically to lead this effort? Or will you lead it?
I will be leading the effort, and we do have an expert team of folks who will be working on this. Dave Cassel, the executive director of Carequality, will be involved, and he has been instrumental with the operational rollout of Carequality. We feel that we have a very strong team.
Is there clarity regarding how many QHINs there might be? Are regional HIEs big enough to be QHINs?
That’s yet to be determined. Some organizations have identified that pursuing QHIN status is a goal of theirs. It’s an evolving market, and some might see this an opportunity to expand their functionalities or capabilities to support what’s expected of the QHINs.
And I think a QHIN could be a network of any size. Ultimately, it will depend on the incentives to become a QHIN and the opportunities for information sharing. But I don’t think the QHIN construct is limited by size, and I [expect] we will see networks of various sizes. We do still need to work through what the final iterations of those requirements to be a QHIN are, through the technical framework and Common Agreement with ONC, and stakeholders at large. So it depends on if the health information network is able to meet the criteria.
Some HIEs have shown concern that this framework will force them to renegotiate their data-sharing agreements with health systems and other large groups like the DoD. Is that an unrealistic concern?
This is where we will have to work very carefully with ONC and all stakeholders—both public and private healthcare organizations and networks—to make sure we can leverage the legal infrastructure we have in place as much as possible, and to minimize the need to renegotiate agreements. It’s something we have our eye on and recognize that changing legal agreements in place can be an extensive process. But we are hopeful that there’s enough feasibility, and again with the input of a community at large, that we will have a common agreement and a TEFCA approach that will align with existing capabilities and agreements as much as we can.
Some have argued that the bar for participation should be pretty low to allow everyone to get in on the ground floor and participate. Do you agree?
We need to get into the details and figure out what the appropriate level is. The reality is that there’s a lot of information being exchanged today within and among participants in health information networks. I think the market has identified an appropriate threshold for enabling information exchange. With anything new there will be questions, and we will need to work with the community to make sure it’s calibrated to what’s realistic.
We are comfortable in facilitating those types of discussions as we have a lot of experience in navigating and working through complex issues, with great success. So we will apply that open and transparent process to make sure there’s buy-in and agreement. Ultimately we want the Common Agreement to not only be completed, but to be used and successful. So we will apply the discipline and the process we have employed over the last decade to do that.
How do you respond to those who contend that TEFCA might infringe on some of health information exchange success that has already taken place across the U.S.?
We will align as much as possible by including those who are already participating in health information exchange, and other stakeholders, to help inform and shape what this looks like. We have to have the buy-in of all the stakeholders—those directly involved and the end users—of what will ultimately be an interoperable health IT ecosystem. It’s about providing a forum so that all who have a stake in this can have a voice in the process.
How do you plan to ensure that stakeholders of all different types and sizes will be included?
That is absolutely foundational, and it’s something we significantly highlighted in our proposal. We do plan to leverage our Interoperability Matters [initiative], which is a public-private cooperative formed in 2018 focused on bringing together various stakeholders to identify and work on tough interoperability challenges. That includes a process to have representative stakeholders involved, as well as public input. We think that public-facing process is extremely important to allow [all] organizations and individuals to have a voice in the process and have visibility into what’s going on. Having an open and transparent process for the RCE is necessary to assure that there is public trust in this work.
What is the short-term timeline going to look like as we move forward?
We are going to get up and moving right away. There is a very aggressive timeframe [in place], so we are hitting the ground running. We have a plan and we are ready. We have been reviewing the public comments on TEFCA because it’s germane to our work and we felt it was important to understand. We know that the RCE needs to take into account public comments in developing the initial draft of the Common Agreement, and there will be an opportunity for further public comment once the initial draft of the Common Agreement is made public. There’s a lot of work to do in a short period of time.
