Just weeks after receiving voluminous comments from all corners of the healthcare industry about its proposed rules for the data exchange provisions of the 21st Century Cures Act, the Office of the National Coordinator for Health IT is getting an earful about another set of interoperability regs.

Among the groups responding this week to ONC's Trusted Exchange Framework and Common Agreement Draft 2 are HIMSS (the parent company of Healthcare IT News), the Sequoia Project, the UCSF Center for Digital Health Innovation and others.

Build on the successes of state and regional HIEs

For its part, HIMSS, along with its Personal Connected Health Alliance, encouraged ONC to make sure it's leveraging existing interoperability efforts to the fullest extent possible as it rolls out its TEFCA roadmap.

HIMSS and PCHA said they have concerns about "the proposed structure and the impact that it could have on existing exchange processes."

For instance, in calling on ONC to relax requirements for provisional Qualified Health Information Network status and give a "longer glidepath" for organizations to fully adhere to the drafted Common Agreement, asked the agency to "not disrupt the existing successful business models of state and regional HIEs and HINs as well as other exchange entities."

Instead, it should "build upon their innovations, partnerships, and successes thus far," enabling QHINs to "maintain their provisional status for a significant period of time" while eventually developing "additional, more ambitious capabilities, exchange modalities, and exchange purposes, that could be met by adapting the existing ecosystem of HIEs and HINs."

Among HIMSS and PCHA's other suggestions to ONC:

• Expand exchange modalities to include push transactions
• Streamline the exchange purposes in the initial roll-out, but ensure TEFCA is positioned to expand activities
• Ensure a robust role for connected care use case in the future framework
• Align privacy and security obligations across the healthcare landscape
• Push for the creation of a patient-focused and driven QHIN
• Clarify the role of QHINs in future uses of patient data

Don't duplicate existing mechanisms of exchange

In its comments, interoperability collective The Sequoia Project offered a series of detailed technical suggestions for how TEFCA Draft 2 can be even further improved since the first go-round.

Among its bigger-picture suggestions, Sequoia echoed HIMSS' sentiment that ONC to be "very mindful to "avoid disruption and duplication of existing exchanges between participants of health information networks."

As currently drafted, said Sequoia officials TEFCA "would both disrupt and duplicate existing exchange mechanisms and would require extensive changes to existing activities and revisions to the terms of thousands of legal agreements."

Of specific concern, the group pointed to the potential need to "revise legal agreements that have, in many cases, taken years to be developed and executed in support of large-scale information sharing."

Sequoia also emphasized that TEFCA should ultimately "address real, material gaps in current exchange networks, frameworks and agreements," noting that a specific area where it could to a lot of good is with the "harmonization of agreed upon purposes for exchange and use of information."

Leverage APIs, align with other proposed rules, give patients more options

TEFCA should prioritized standardized application programming interfaces, like the other recent proposed regs from ONC and the Centers for Medicare and Medicaid Services, said researchers from the UCSF Center for Digital Health Innovation in comments submitted to ONC.

"These two networks – TEFCA, and ONC and CMS’s standardized API exchange – must be fully interoperable and able to leverage each other," said the group in its letter to ONC. "Without such a requirement, a Trusted Exchange Framework for document-based exchange will never provide the interoperability that Congress, ONC, CMS, and the nation all expect with forthcoming standardized APIs."

Moreover, TEFCA use cases for patients should be broadened beyond just HIPAA requests for medical records and sharing with third parties, according to UCSF – offering an "on-ramp" for patients that's as valuable as the one for providers.

"Patients need and use interoperability for the spectrum of health care needs, not just exercising these two rights under HIPAA’s Privacy Rule," said the group. "ONC should broaden Individual Access Services to include other core health use cases for patients and individuals so that they have a full and equal on-ramp."