In January 2018 the Office of the National Coordinator for Health Information Technology (ONC) issued a draft Trusted Exchange Framework and Common Agreement (TEFCA), and related supporting documents, in response to a requirement imposed by Congress in the 21st Century Cures Act. The Act says that the TEF may include a common method for authenticating users, a common set of rules, enabling policies, and a process for managing non-compliance. Nowhere does the Act instruct ONC to determine an actual technical architecture in this process, though such a step is not precluded either.
The primary document is in two parts: Part 1 is a set of principles that set the foundation for Part 2 which is a set if minimum terms and conditions for trusted exchange. While the principles seem overall quite reasonable, the terms and conditions have many, many technical specifications and standards embedded within them and lay the groundwork for a very specific nationwide implementation. Though the phrase “network of networks” appears nowhere in these documents, Part 2 seems to describe a technical implementation not too unlike the original NwHIN/eHealth Exchange model that was implemented with limited success a number of years ago. It does not appear that this model fits all that well with any of the major market-based strategies that have emerged in the past several years, notably the Commonwell Health Alliance, Carequality, or the Strategic Health Information Exchange Collaborative (SHIEC).