Comments on the Draft Trusted Exchange Framework
Below is the letter EP3 Foundation sent in reply to the ONC Draft Trusted Exchange Framework:
Dear Dr. Rucker,
The EP3 Foundation welcomes this opportunity to provide comments on the Draft Trusted Exchange Framework released by the Office of the National Coordinator for Health Information Technology (ONC) on January 5, 2018.
We applaud the commitment of the ONC to promote innovation at all levels. We believe that forward-thinking innovations are critical for the ONC to realize the vision of empowering every individual to use their electronic health information to the fullest extent, and to enable providers and communities to deliver smarter, safer, and more efficient care.
At its core, the Trusted Framework must provide the capacity for any individual, in their roles in the healthcare ecosystem, or as the patient, to find, access, and aggregate the information needed to improve health outcomes and efficiencies.
We believe that innovation and new thinking are essential for the Trusted Framework to simultaneously enable patient-centered data exchange, population analytics and patient empowerment, while at the same time protecting privacy and ensuring regulatory compliance. Thus, the Trusted Exchange Framework Common Agreement (TEFCA) should not be overly prescriptive, and be open to innovation that uses pseudonymous information, privacy-preserving obfuscation, shared cloud services for fine-grained access control and privacy-preserving analytics that more effectively supports all of the Permitted Purposes, yet without risking privacy or regulatory compliance.
To encourage, foster, and reward innovation, the ONC must encourage the private sector to compete to develop QHINs and Connectivity Brokers based on diverse and innovative approaches, give them a fair opportunity to demonstrate their viability and define objective criteria for comparing how well various approaches satisfy the Framework principles. Without comparing and testing new approaches, the traditional roadblocks to interoperable trusted exchange will remain unresolved. The following document articulates the EP3 Foundation’s recommendations and comments that we believe are a catalyst to new, effective approaches to trusted exchanges and network interoperability.
John C (Jack) Lewin, MD
Board Chair, EP3 Foundation
Chairman of The National
Coalition on Health Care (NCHC)
President and CEO