On 8/16/24, Epic and Carequality made dual announcements that on the surface may seem fairly innocuous, but they actually made a huge statement about the future of nationwide data exchange. 

We asked Zen Healthcare IT President, Marilee Benson, to provide some background and share her assessment on the potential impacts of these announcements so your organizations can better prepare for that future.

Introduction & History

In 2014, Epic helped establish the Carequality National Exchange Framework. While seemingly a reaction to Cerner establishing Commonwell Alliance, Carequality went further, recognizing that the future of data exchange was a “network of networks”, and thus Carequality was built as a trust framework that would support “network to network” exchange.  

Today, almost 1B clinical documents are being exchanged via the Carequality framework, which includes Commonwell Alliance and eHealth Exchange (and their participants who elect to “opt in” to Carequality based exchange). 

When TEFCA was created, and The Sequoia Project was selected as the Recognized Coordinating Entity (RCE), it was pretty clear to those of us with a long history in nationwide data exchange, that the Carequality “framework” would be the starting place for TEFCA – QHIN based exchange. Under TEFCA, the QHINs (Qualified Health Information Networks) are the networks exchanging data with each other, and each will have their own participants. 

TEFCA also opened up the opportunity to expand beyond “treatment” data exchange use cases, and mandate Individual Access Services – finally bringing the patient into the data exchange picture. Carequality has been very successful at enabling Treatment based exchange, with mandatory reciprocity driving adoption. But other data exchange purposes have remained poorly adopted. The best example is direct patient access to their data, which has been a huge need with very low adoption, as it was never successfully made a mandatory “purpose of use” under Carequality TEFCA mandatory Individual Access will fix this problem . 

TEFCA went Live in December 2023 – Now What?

Since TEFCA went live in December of 2023, the industry has had some questions about what this means to existing nationwide data exchange initiatives:

1) TEFCA isn’t mandatory – what will be the driver for health organizations to join up, and move from successful data exchange through the existing networks, such as Carequality?  

2) Assuming drivers emerge, what will be the timing for this massive shift from existing data exchange networks to TEFCA?

With the recent Carequality and Epic announcements below, we just got our answers.

On 08/16/24 – Epic and Carequality Make Dual Announcements

Those of us who spend our days closely monitoring news in the healthcare interoperability space had some interesting emails pop into our inboxes on 8/16/24.

Carequality announced that they would be closely aligning with recent updates made in TEFCA written policies (called SOPs).  Now – instead of Carequality influencing TEFCA, TEFCA is influencing Carequality. Carequality includes the word “transition” in their announcement. As in – more closely aligning with TEFCA will allow for an easier transition to TEFCA later.

Shortly thereafter, Epic posted an announcement in a fairly innocuous location on their website, congratulating Carequality for making the decision to further align with TEFCA’s policies, and most importantly, added some additional comments: Epic is asking all its customers to commit to participating in TEFCA based exchange by the end of 2024, and transitioning to TEFCA based exchange by the end of 2025. 

Folks, I have no inside information, but I am pretty confident – that “transition” means a massive shift of Epic customers moving away from Carequality and over to TEFCA via Epic’s QHIN between now and the end of 2025. And this should not be a surprise. Epic and others have made a big investment to become QHINs. This is the next natural step for them. It’s the one we’ve all been waiting for.

What does this mean for TEFCA?

As of 8/16/24, Epic (and Carequality) have answered the questions we’ve always had about TEFCA.

1.  EPIC is the driver to TEFCA adoption as one of the biggest holders of EMR data in the country. When Epic announces that they are asking all their clients to transition to TEFCA, everyone else is going to have to follow them or Risk losing the ability to query Epic customers via the national networks.
2. NOW is the time to plan for TEFCA based nationwide data exchange. Healthcare organizations and HealthTech vendors have between now and the end of 2025 to put a QHIN strategy into place, unless you (or your clients) do not need to exchange data broadly across the healthcare ecosystem.

What does this mean for Carequality?

Many people think that without Epic, Carequality won’t be able to sustain itself.  I am not 100% sure that is true, but I do think Carequality will look very different a year from now.  

“Looking different” might not be a bad thing. Perhaps Carequality remains a viable path to other sources of healthcare data. Or becomes a testing ground for new data exchange use cases that are not on the ONC’s radar, but nonetheless offer real value to the healthcare ecosystem. 

Most of Zen’s clients are already participating in multiple data exchange networks through our Gemini+Stargate platform, reflecting the real differences between the networks. QHIN based exchange will become another “tool” in our client’s overall data exchange toolbox.

Action Plan for a Transition to TEFCA based exchange

1. Evaluate your current network participation. If you are already a member of eHealth Exchange or Commonwell Alliance, both are also QHINs, and will help accelerate QHIN access. Be sure you understand the steps you’d need to take to “opt in”. If you are a Zen client already, we’ll be supporting you in that effort, and doing most of the work for you.
2. If you don’t have QHIN access today, talk to folks like Zen who have expertise in nationwide data exchange and can discuss with you the different options available for QHIN access. 
3. If you operate your own gateway for national network access, now is the best time to be considering your go forward path. QHIN technical specifications are even more complex, with new code sets, new SAML requirements, and new TEFCA directory requirements.  You’ve never needed a “nationwide data exchange” trusted partner more than you need one now. Zen has been doing a number of gateway replacements in the past year, and “future proofing” for a period of rapid changes in network based exchange has been a big driver.
4. While it’s important to get familiar with TEFCA based exchange – it can be a big effort to get up to speed. And you may only really need to understand a subset of the overall TEFCA requirements. Zen is helping our clients focus on what they really need to know, versus what can easily become a distraction.