TEFCA and CMS-Aligned Networks: Two Paths to Accelerating Health Data Interoperability
A new wave of initiatives is aiming to streamline health information exchange, with the Centers for Medicare & Medicaid Services (CMS) launching an ambitious Health Technology Ecosystem pledge program in July. The program has generated significant momentum, and represents a key step toward a more connected healthcare system.
The ultimate goal of both the Trusted Exchange Framework and Common Agreement™ (TEFCA) and the CMS-Aligned Network pledge is to improve interoperability – the ability of diffrent health IT systems to exchange and use electronic health information.According to a statement from CMS, the agency created the CMS-Aligned Network pledge criteria to provide a pathway for any network to accelerate its interoperability capabilities, irrespective of its existing business model.
TEFCA, stemming from the 21st Century Cures Act, establishes a “Common Agreement” for network-to-network exchange. CMS, however, has challenged networks to “do more, faster” through the voluntary CMS-Aligned Network pledge. Any organization identifying as a network and agreeing to meet the standards outlined in the CMS Interoperability Framework can participate. notably, all organizations currently designated as Qualified Health Information Networks™ (QHINs™) under TEFCA have also committed to being CMS-Aligned Networks, highlighting the synergistic potential of the two approaches.
While TEFCA provides a centralized governance structure, the CMS-Aligned Network pledge relies on CMS to actively define expectations and convene technical working groups. Pledgees commit to shared goals, contribute to common approaches, and are expected to demonstrate continuous progress. CMS retains the authority to remove organizations that fail to meet the criteria,and organizations can voluntarily withdraw if their priorities shift. All CMS-Aligned Networks are required to meet HITRUST requirements and maintain full compliance with HIPAA rules and all other applicable privacy and security regulations.
TEFCA, which went live at the end of 2023, operates under a participatory, public-private, collaborative governance model. Becoming a QHIN requires rigorous adherence to specific requirements, including cybersecurity insurance, annual third-party security assessments, and U.S.ownership status. qhins must also ensure their Participants and Subparticipants adhere to specific terms of participation – a level of operational policy not required for the CMS-Aligned Network pledge program.
Speedboats and Rising Tides: Different Approaches to Interoperability
One analyst noted that TEFCA functions as a “rising tide that lifts all boats,” while CMS-Aligned Networks are more akin to “speedboats shooting out ahead” to achieve specific milestones. Such as, the CMS Interoperability Framework requires CMS-Aligned Networks to provide a detailed “accounting record” of all network-facilitated transactions – including who accessed patient data, when, and why – and to ensure timely responses to each request. Furthermore,the framework mandates that patient consent preferences be shared with all involved parties.
These criteria represent a significant leap beyond current policy baselines, demanding a level of automation and process standardization that is not yet universal in healthcare. The CMS Interoperability Framework also prioritizes “patient appointment and encounter details” for accelerated effort, a use case not necessarily central to TEFCA’s focus on cross-network exchange.
Despite these differences, TEFCA and the CMS Interoperability Framework share common ground in their underlying technical expectations, both referencing support for USCDI, HL7® FHIR®, and IAL2 and AAL2 for digital identity, as well as was to be expected capabilities for record location and query.
The core distinction lies in pace and structure. TEFCA follows a formal, stepwise governance process, while CMS-Aligned Networks operate within an ongoing, “connect-a-thon” style model that encourages rapid testing, learning, and refinement. These two approaches are fundamentally complementary – one providing stability, the other accelerating innovation.
Ultimately, the success of TEFCA will be amplified by the achievements of CMS-Aligned Networks. Collectively, these efforts will empower patients with greater control over their electronic health information and leverage interoperability to reduce administrative burdens. We look forward to continuing to advance TEFCA and remain committed to its growth.
