FEBRUARY 20, 2018
Dr. Donald Rucker, National Coordinator for HIT
Office of National Coordinator
U.S. Department of Health and Human Services
330 C St SW
Washington, DC 20201
Proposed Trusted Exchange Framework and Common Agreement Comments
Dear Dr. Rucker,
Great Lakes Health Connect (GLHC) appreciates the opportunity to comment about the proposed Trusted Exchange Framework and Common Agreement (TEFCA). As the premier health information network (HIN) in Michigan and one of many leading privately sustainable HINs in the nation, GLHC seamlessly and securely facilitates the transmission of more than a billion messages annually on behalf of over 9.5 million persons between 129 hospitals/ health networks and over 4,000 primary, specialty, behavioral, social service, and allied care offices across Michigan. In addition, a majority of the data received by Michigan’s network-ofnetworks designated entity for state use cases originates at GLHC. GLHC is a communityfocused nonprofit with boots on the ground dedicated to improving the quality and accessibility of healthcare information by creating care-connected communities across Michigan, the Great Lakes region, and the nation overall.
GLHC, and other HIEs nationally, have a unique perspective given our role as trusted local facilitators in making interoperability work. We do this work daily across physical, behavioral, social service, payer, and other stakeholders involved in the broad local healthcare ecosystem. Unlike the perspective of others who operate far away from the end users who need to make interoperability work every day, HIEs work day to day in the trenches with these users to drive value in their workflows. We appreciate ONC’s interest in hearing the HIE perspective over the years and encourage you to continuing doing so to best understand the local ramifications of national decisions.
GLHC is a member of the Strategic Health Information Exchange Collaborative (SHIEC) which serves over 60 member HIEs across the country and covers over 75% of the United States population. SHIEC is committed to being a part of the national interoperability solution. Patient Centered Data Home (PCDH) is a primary example of SHIEC’s efforts to achieve national interoperability. PCDH is a cost-effective, scalable method of exchanging patient data among HIE networks coast-to-coast. GLHC strongly encourages ONC to consider PCDH’s success in driving meaningful national exchange, and fully leveraging it moving forward to achieve its interoperability goals.
GLHC offers the following comments and recommendations for consideration as ONC develops TEFCA.
- We support the ONC and believe a common national framework for exchange is necessary and an important piece of the interoperability picture, but believe it is only one piece of the puzzle.
- Focus first on establishing the connectivity between current national networks and then systematically increase the level of sophistication based on participant interest and financial sustainability.
- Given the new requirements outlined in the TEFCA proposal, the timeframes for implementation are overly aggressive.
- Expand thoughts relative to overall governance and monitoring within the proposed framework.
Great Lakes Health Connect was incorporated with the sole purpose to enable and facilitate the exchange of health information within and between the broad healthcare ecosystem in Michigan. Sharing data with and getting access to data from organizations outside of Michigan as people seek care or travel otherwise beyond our borders has always been a key point on our roadmap. We are one of the early adopters of Patient Centered Data Home and are transacting hundreds of thousands of messages each year just between our Heartland partners alone.
We appreciate ONC’s leadership in the area of national interoperability and are eager to work with you to integrate our sophisticated local interoperability and HIE components with an evolving national interoperability framework. Most healthcare is local. If local and national interoperability efforts are not aligned we will not create the easy, cost-effective overall framework that will best support healthcare stakeholders and the consumers/patients they ultimately serve. Together, we can create a seamless, full featured framework over time that fully leverages the best local and national work and investments and results in the vision to which we strive.