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TEFCA

The Trusted Exchange Framework and Common Agreement is the federal framework, created under the 21st Century Cures Act, for nationwide exchange of electronic health information. The Office of the National Coordinator (now the Assistant Secretary for Technology Policy) sets policy, and The Sequoia Project, as Recognized Coordinating Entity, administers it.

Networks that meet the requirements sign the Common Agreement and are designated Qualified Health Information Networks; the first QHINs were designated in December 2023. Health systems, vendors, and payers join as Participants or Subparticipants by signing flow-down agreements with a QHIN.

A QHIN must be a U.S. entity, complete the application and onboarding process (about twelve months, including a twelve-month provisional period), pass conformance testing against the QHIN Technical Framework, and hold third-party security certification; the RCE has designated HITRUST r2 as the accepted certification.

In writing, a QHIN needs the signed Common Agreement, its governance and participation policies, privacy and security policies meeting the Common Agreement and applicable standard operating procedures, the security certification report, incident response and breach notification procedures, and records showing compliance with the exchange purposes and individual access rules.

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Who has to comply

Participation is voluntary. Requirements bind health information networks that seek QHIN designation and, through flow-down terms, the Participants and Subparticipants that connect through them. Certified health IT developers face related information sharing obligations under separate ONC rules.

What the assessor asks to see

The RCE and assessors ask for the signed Common Agreement and U.S. ownership questionnaire, governance documents and participation policies, the QHIN Technical Framework test results, the HITRUST r2 certification report, privacy and security policies and the risk assessment, incident response and breach notification procedures with records, audit logging evidence, Participant and Subparticipant agreements with flow-down terms, and records of exchange purpose handling and individual access services.

Key dates

Common Agreement version 1 published January 2022; first QHINs designated December 2023; Common Agreement version 2.x and updated SOPs issued in 2024 and 2025. The QHIN Onboarding and Designation SOP was updated in January 2025 (version 3).

Who helps with TEFCA

Health information exchange consultancies, HITRUST assessor firms, and the QHINs themselves, which onboard Participants. Engagements for prospective QHINs run through the RCE's five-phase application and onboarding process; for Participants, the work is contracting, technical connection, and policy alignment.

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Consultants

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Who assesses TEFCA

The RCE reviews applications, oversees conformance testing, and monitors QHINs. Security certification is assessed by HITRUST authorized external assessor firms under the HITRUST r2 program. There is no other third-party certifier for TEFCA itself.

Accredited by The RCE, under ONC/ASTP oversight, designates QHINs. HITRUST authorizes its external assessor firms.

Assessors

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Tools for TEFCA

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Related reading

  1. Understanding TEFCA: A National Step Toward InteroperabilityA nonprofit health information exchange explains the network-of-networks design and what joining through a QHIN actually changes for a provider.Contexture
  2. A Technical Guide to TEFCA IntegrationDeveloper-level walkthrough of participation models, QHIN connectivity, exchange purposes and the security obligations that come with each.Medplum

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