Policy letter to ONC for HIT on ONC’s Trusted Exchange Framework Draft 2 for national interoperability

UCSF’s Center for Digital Health Innovation recommends that ONC require Trusted Exchange Framework participants to include access and transmission through standardized application programming interfaces (APIs).  The two networks—TEFCA, and ONC’s and CMS’s standardized API exchange—must be fully interoperable and able to leverage each other.  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.

Secondly, Draft 2 limits patients’ use of the Trusted Exchange Framework to requests for a copy of one’s health information, and directing that a copy be sent to a third party.  Patients need and use interoperability for the spectrum of health care needs, not just exercising these two rights under HIPAA’s Privacy Rule.  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.