February 2, 2018
Don Rucker, MD
National Coordinator for Health Information Technology
Office of the National Coordinator for Health IT
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201
Re: Draft Trusted Exchange Framework and Common Agreement
Dear National Coordinator Rucker:
The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to publication of the draft Trusted Exchange Framework and Common Agreement (TEFCA). MGMA supports the Office of the National Coordinator for Health Information Technology (ONC) efforts to facilitate the deployment and utilization of electronic health information exchange across providers and other stakeholders.
MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, advocacy and education, MGMA empowers medical group practices to create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.
Passage of the bipartisan 21st Century Cures Act creates the opportunity to define and promote the development of a nationwide interoperable health information exchange infrastructure. However, the foundations of interoperability-cooperation, trust, and confidence among all stakeholders who seek to exchange information, must be solidified if the industry is to successfully move forward. With the release of this draft document, ONC has outlined an infrastructure blueprint that we hope will accelerate deployment and adoption of effective and efficient data exchange process.
By proposing a single “on-ramp” for exchange participants, ONC is seeking to leverage the current system of multiple Health Information Networks (HINs) rather than replace them with a single entity. MGMA agrees that moving to a single HIN would significantly disrupt the healthcare system, jeopardize stakeholder infrastructure investments made to date, and require considerable federal dollars to implement. We support the overall approach presented in the TEFCA of establishing a single on-ramp to electronic health information sharing that seeks to facilitate data exchange regardless of the participant’s chosen network. We believe that TEFCA both exploits the considerable progress the industry has made in recent years to electronically exchange patient health information and promotes a set of standards that qualified networks must adhere to. We assert that, once implemented, this framework will create the confidence necessary to significantly expand the exchange of patient data to and from physician practices.