Premier provided comments on the second draft of the Trusted Exchange Framework and Common Agreement (TEFCA), the federal design to create a national “network of networks” through which patient data will be exchanged. TEFCA outlines principles, terms, and conditions to support the development of a Common Agreement among participating networks. Among Premier’s comments, we recommended:
- Pilot testing, including phasing in cohorts of qualified health information networks.
- Reducing provider burden, including by identifying anticipated stakeholder technology and infrastructure investments as well as ongoing operational changes and enhancements.
- Disclosure of any fees that could be imposed on healthcare providers.