CMS launched an interoperability pledge program in July to spur information-sharing efforts. But how does it differ from TEFCA, aka the Trusted Exchange Framework and Common Agreement?
Steven Posnack, principal deputy assistant secretary for technology policy at HHS, addressed that question in a Dec. 16 blog post. Here are five things to know:
1. TEFCA and CMS-aligned networks are both aimed at secure, nationwide health data exchange to improve care and reduce administrative burden. CMS designed its pledge program to complement, not replace, TEFCA — and all current TEFCA-qualified health information networks, or QHINs, have also pledged as CMS-aligned networks.
2. TEFCA fulfills the 21st Century Cures Act’s mandate to standardize interoperability governance and create a nationwide network-to-network exchange. CMS-aligned networks, by contrast, are a voluntary way for networks to publicly commit to “do more, faster.”
3. TEFCA operates through a rigorous, “stepwise” governance model with detailed onboarding, oversight, and enforcement requirements. CMS-aligned networks operate more like an “ongoing connect-a-thon” — emphasizing rapid testing, iteration, and progress toward ambitious interoperability criteria.
4. Becoming a QHIN under TEFCA requires meeting strict technical, legal and security standards — including cybersecurity insurance, third-party security assessments, U.S. ownership requirements, and enforcing participation rules across downstream members. CMS-aligned networks do not impose that level of operational control.
5. TEFCA is the “rising tide that lifts all boats,” while CMS-aligned networks are “speedboats” racing ahead on specific use cases like patient appointment and encounter data. Stability from TEFCA and innovation from CMS-aligned networks are meant to reinforce each other.
