Managing healthcare IT in 2025? TEFCA is more than just another acronym. It’s the federal government’s bold move to end the data silos that have long held patient information captive.
The Office of the National Coordinator for Health Information Technology has launched TEFCA. It aims to create a single gateway for nationwide health data exchange. This enables seamless sharing of electronic health information across all healthcare settings in the country, promoting optimal interoperability.
The vision is clear: a patient’s visit to your clinic should instantly reveal their full medical history. That includes records from specialists and ER visits, no matter where they are in the country.
For healthcare providers, participation in TEFCA is voluntary, though many organizations are choosing to connect via a Qualified Health Information Network to simplify nationwide exchange. It’s the new standard.
At Mediportal, we’ve designed our EMR software with these federal mandates in mind. This section will help you understand how these regulations impact your daily operations and compliance needs.
Key Takeaways
- TEFCA sets standardized, nationwide “rules of the road” for health data exchange via QHINs; participation by providers is voluntary.
- TEFCA provides a “single on-ramp” to a network-of-networks (QHINs) to enable cross-network exchange for defined Exchange Purposes.
- Healthcare providers must connect with Qualified Health Information Networks to meet federal compliance requirements
- Patient data can now flow seamlessly across hospitals, clinics, labs, and specialists nationwide
- The Office of the National Coordinator for Health Information Technology oversees TEFCA implementation and enforcement
- Mediportal’s EMR platform is built to navigate these federal interoperability requirements from the ground up
Understanding TEFCA and the ONC Framework for Health Information Exchange
For decades, health information exchange in America was fragmented. TEFCA has brought order to this chaos. The Trusted Exchange Framework and Common Agreement for nationwide health information interoperability is the federal government’s most ambitious attempt at establishing a universal set of rules and technical standards. It’s not just another policy document.
It’s a framework that changes how healthcare organizations share patient data nationwide. At Mediportal, we’ve closely watched this evolution. Our M-Power EHR is designed with interoperability at its core, ensuring providers can exchange data securely and efficiently while staying compliant with federal standards.
What is the Trusted Exchange Framework and Common Agreement
TEFCA consists of two components: the Exchange Framework and the Common Agreement. The Exchange Framework establishes technical standards and operational requirements for EHR data integration. It’s like a technical blueprint, specifying data formats, query structures, and security protocols.
The Common Agreement is the legal and governance contract. When organizations sign it, they accept privacy practices, security standards, and operational requirements. This creates trust within TEFCA.
This approach is revolutionary. Instead of negotiating individual agreements, you connect through a Qualified Health Information Network (QHIN). Once you’re connected, you can exchange data with every other TEFCA participant nationwide.
TEFCA evolved from earlier federal initiatives, like the Nationwide Health Information Network (NwHIN) and its Data Use and Reciprocal Support Agreement (DURSA) published in January 2009. Those efforts laid the groundwork but never achieved nationwide interoperability. TEFCA created stronger governance and clearer participation requirements.
The Sequoia Project is the TEFCA Recognized Coordinating Entity (RCE), managing the framework’s operations. QHINs are the on-ramps to this national network, meeting rigorous standards and signing agreements for trusted exchange.
When considering participation in tefca, remember: the framework resolves years of fragmentation. It establishes common standards and unified governance. You’re not just connecting to one partner—you’re joining a national ecosystem.
| TEFCA Component | Primary Function | Key Requirements | Oversight Authority |
| Exchange Framework | Technical standards and operational specifications | Data formats, security protocols, query structures | ONC certification criteria |
| Common Agreement | Legal contract and governance rules | Privacy practices, security standards, operational commitments | Sequoia Project as RCE |
| QHIN Network | Connection infrastructure between participants | Technical capability, security compliance, agreement execution | RCE with ONC oversight |
| Participant Organizations | Healthcare entities exchanging data | Connection through QHIN, adherence to Common Agreement terms | QHIN and RCE monitoring |
The Office of the National Coordinator for Health Information Technology and Its Regulatory Role
The Office of the National Coordinator for Health Information Technology (ONC) sits within the Department of Health and Human Services. It carries significant regulatory authority over medical information technology nationwide. ONC doesn’t just make suggestions—they establish binding requirements for your EMR systems to participate in federal programs and achieve interoperability.
ONC’s primary regulatory tool is the Health IT Certification Program. It sets criteria for the use of electronic health information systems. If your EMR isn’t ONC-certified, you can’t participate in federal meaningful use programs, quality reporting initiatives, or TEFCA itself. The certification criteria align with the technical requirements of the exchange framework and common standards for data exchange.
Beyond certification, ONC has the mandate to publish TEFCA on its website and in official government channels. When ONC publishes requirements in the Federal Register, those requirements carry the full weight of federal law. This isn’t administrative guidance you can choose to follow or ignore—it’s a legally binding regulation.
ONC designated the Sequoia Project as the Recognized Coordinating Entity for TEFCA operations. This includes managing the provision of the Common Agreement, qualifying and monitoring QHINs, and facilitating exchange between health information networks. ONC retains oversight authority and can intervene when issues arise.
The Office also coordinates with other federal agencies on public health data exchange requirements. It works to ensure TEFCA supports broader health policy objectives. When evaluating your interoperability strategy, understanding ONC’s role helps you recognize which requirements are mandatory versus which are best practices.
Department of Health and Human Services Oversight and Federal Register Requirements
The Department of Health and Human Services (HHS) provides the overarching oversight umbrella for TEFCA. It ensures coordination with other federal health initiatives. HHS enforcement mechanisms give teeth to TEFCA requirements through several channels, including HIPAA privacy and security enforcement, information blocking penalties under the 21st Century Cures Act, and Medicare/Medicaid participation requirements.
When certain provisions related to TEFCA are published in the federal register, HHS gains the authority to enforce compliance. The Federal Register publication process transforms policy proposals into binding federal regulations. You’ll see notices of proposed rulemaking, public comment periods, and final rules that carry enforcement authority.
Learn More: Federal Register: TEFCA Final Rule (45 CFR Part 172)
HHS also coordinates TEFCA implementation with broader federal health policy goals. The department ensures the common agreement aligns with HIPAA privacy rules, supports public health reporting requirements, and advances health equity objectives. This coordination matters because your organization faces overlapping requirements from multiple federal sources—TEFCA doesn’t exist in isolation.
The enforcement dimension is critical to understand. HHS can investigate violations, impose financial penalties, and in severe cases, exclude organizations from federal healthcare programs. When evaluating your compliance posture, you’re not just checking boxes—you’re managing real regulatory risk.
At Mediportal, we’ve built our interoperability solutions to align with this entire governance structure. Our M-Power EHR meets ONC certification criteria, supports the technical requirements for connection through QHINs, and includes the privacy and security controls that the common agreement demands. We handle the complex compliance requirements so you can focus on patient care.
Federal Requirements for Interoperability TEFCA Compliance
Let’s dive into the specifics of TEFCA compliance. Understanding the framework is just the beginning. You must implement technical capabilities, follow privacy protocols, and maintain certification. We’ll guide you through each key component to make sure your organization meets the necessary standards.
These requirements are not optional. They are mandatory for your health IT systems and are legally required to participate in TEFCA and in nationwide interoperability networks.
ONC Health IT Certification Program For Health Information Technology and Criteria
Your EMR system must adhere to the ONC Health IT Certification Program standards. This program originated from the Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009, allocating nearly $30 billion for electronic health record technology adoption.
The certification program for health information technology is ongoing. It involves a set of technical criteria that your system must continuously meet.
Developers of certified health IT are responsible for ensuring their products meet these standards. You must verify your vendor’s certification status and confirm the correct implementation of certified modules.
The 21st Century Cures Act introduced new requirements. It established information blocking provisions and mandated that certified systems demonstrate they’re “capable of trusted exchange.” Your health IT module certified under ONC standards must support both push and pull methods for health information exchange.
Here’s what the onc certification criteria for health data technology actually require:
- Support for FHIR (Fast Healthcare Interoperability Resources) APIs to enable modern data exchange
- Implementation of C-CDA (Consolidated Clinical Document Architecture) for structured document exchange
- Direct messaging capabilities for secure point-to-point communication
- Standardized clinical terminology including SNOMED CT, LOINC, and RxNorm
- Patient access APIs that allow individuals to retrieve their complete health records
The United States Core Data for Interoperability (USCDI) defines the minimum data elements your system must exchange. This includes patient demographics, allergies, medications, immunizations, lab results, vital signs, and clinical notes. Each USCDI version expands these requirements, so staying current matters.
At Mediportal, we maintain our ONC health IT certification program status continuously. Our platform includes all required electronic data sharing standards built into the core architecture, not bolted on as afterthoughts.
Common Agreement Requirements for Participation With Health Information Networks
Participating in TEFCA means agreeing to a specific set of operational and technical obligations outlined in the Common Agreement. You don’t sign this agreement directly—you connect through a Qualified Health Information Network (QHIN) that has signed the Common Agreement. But you need to understand what you’re committing to.
The most fundamental requirement is supporting full network-to-network exchange of health information. If your organization connects to QHIN A, you must be capable of exchanging data with organizations connected to QHIN B, C, D, and every other QHIN in the network. No cherry-picking which networks you’ll work with.
Organizations that voluntarily elect to adopt TEFCA accept these participation requirements:
| Requirement Category | Specific Obligation | Implementation Impact |
| Data Exchange Scope | Support all permitted exchange purposes | Configure systems for treatment, payment, operations, and public health exchanges |
| Consent Management | Respect patient preferences and consent directives | Implement consent capture, storage, and enforcement mechanisms |
| Data Use Restrictions | Use exchanged information only for permitted purposes | Establish policies and technical controls limiting data use |
| Information Blocking | Avoid practices that interfere with access or exchange | Review workflows to ensure compliance with the Cures Act provisions |
If you’ve adopted the Common Agreement, you should know it includes a critical provision: you must maintain the ability to suspend TEFCA exchange with another participant if they violate agreement terms. You cannot blanket-refuse to exchange data with entire networks or categories of requesters.
The new TEFCA manner exception creates specific circumstances where information blocking rules apply differently. This exception, finalized by ONC, provides clarity on when electronic exchange outside of TEFCA may face different regulatory treatment. The purpose in incentivizing TEFCA participation becomes clear here—organizations exchange via TEFCA gain certain regulatory advantages.
You’ll also need processes for handling edge cases. What happens when a patient requests data suppression? When do mandatory reporting obligations override patient preferences? The Common Agreement provides frameworks for these scenarios, but you need operational procedures to implement them.
Privacy and Security Standards Under TEFCA
TEFCA builds on the foundation of the Health Insurance Portability and Accountability Act (HIPAA) but extends requirements in meaningful ways. The privacy and security certification framework demands a wide range of safeguards across technical, administrative, and physical domains.
Technical safeguards form your first line of defense. Your systems must implement:
- End-to-end encryption for data in transit and at rest
- Role-based access controls that limit who can view specific information
- Comprehensive audit logging that tracks every access to health information
- Automatic session timeouts and re-authentication protocols
- Intrusion detection and prevention systems
Administrative safeguards require formal policies and procedures. You need documented information security policies, regular workforce training programs, incident response plans, and business associate agreements with all vendors who handle health data.
Physical safeguards protect the hardware and facilities where electronic health information lives. This includes facility access controls, workstation security policies, and device and media disposal procedures.
Patient access to health information represents a cornerstone privacy requirement. Your certified systems must provide patients with API-based access to their complete health records. This isn’t just about patient portals—it’s about enabling patients to direct their data to any third-party application they choose.
The states core data for interoperability must be handled with particular care. USCDI data elements flow across organizational boundaries, requiring consistent security practices. This is true whether data originated in your system or came from external sources.
Here’s something many organizations miss: the new TEFCA manner exception based on privacy considerations. This provision acknowledges that certain state laws may impose stricter privacy requirements than federal standards. Your compliance approach must account for state-specific regulations, focusing on sensitive categories like mental health, substance use disorder treatment, and HIV status.
Public Health Data Exchange and Agency Requirements
Public health interoperability operates under different rules than clinical care exchange. TEFCA includes specific provisions to advance public health data exchange separate from treatment-related information sharing.
Public health agencies require specialized reporting capabilities. Your certified health IT must support:
- Electronic case reporting for notifiable conditions
- Immunization information system reporting
- Syndromic surveillance data submission
- Electronic vital records reporting
- Cancer registry reporting where applicable
The value of TEFCA in promoting public health became undeniable during the COVID-19 pandemic. Fragmented data exchange systems hampered outbreak response, contact tracing, and resource allocation. Organizations supporting TEFCA for the purpose of public health reporting help build resilient infrastructure for future emergencies.
Public health exchanges often use different technical standards than clinical exchanges. While clinical exchange relies heavily on FHIR and C-CDA, public health reporting may use HL7 v2 messages, specialized flat files, or web service APIs. Your health IT module certified for public health must accommodate these varied protocols.
Timing requirements differ too. Clinical exchange happens on-demand when providers need information for patient care. Public health reporting follows scheduled submission patterns—daily immunization uploads, weekly syndromic surveillance batches, immediate case reports for certain conditions.
Mediportal’s platform handles both clinical and public health exchange requirements through a unified architecture. We’ve built these capabilities into our core system so you’re not managing separate tools for different exchange purposes. Our solution meets ONC certification requirements while providing the workflow integration that makes compliance practical, not just possible.
Conclusion: Achieving TEFCA Compliance with Mediportal
The adoption of TEFCA marks a significant shift in health information exchange across the United States. It’s not just about meeting federal compliance standards. It’s about creating a foundation for enhanced patient care.
Mediportal EMR software stands out in this arena. Our M-Power EHR is designed with interoperability at its core, not as an add-on. By choosing our interoperability solution, you ensure seamless integration with Qualified Health Information Networks (QHINs) from the start.
Adopting the TEFCA framework becomes effortless with a system crafted by certified health IT developers. You seamlessly connect to the nationwide network, facilitating instant and secure data exchange. This aligns perfectly with the needs of patients and healthcare professionals.
Improved care coordination is the direct result of having complete patient histories at your fingertips. This eliminates the need for duplicate tests and reduces medication errors. It empowers clinicians to make informed decisions based on a full understanding of patient data.
By joining Mediportal’s TEFCA program, you’re not only meeting today’s standards but also preparing for future regulations. The health data exchange landscape will evolve, and those with purpose-built interoperability solutions will adapt effortlessly.
TEFCA is more than a regulation; it’s the blueprint for future healthcare collaboration. Providers who embrace electronic health interoperability today will lead in delivering modern, patient-centered care. This is the vision Mediportal has built upon.
FAQ
1. What is TEFCA and why is it important for healthcare providers in 2025?
TEFCA (Trusted Exchange Framework and Common Agreement) is a federal framework established by the Office of the National Coordinator for Health Information Technology that enables nationwide health information exchange. It creates a single gateway for seamless data sharing across all healthcare settings, allowing patient records from hospitals, clinics, specialists, and emergency rooms to be accessed instantly. Healthcare providers must connect with Qualified Health Information Networks to meet federal compliance requirements and participate in this national ecosystem.
2. What are the ONC Health IT Certification requirements for TEFCA compliance?
The ONC Health IT Certification Program requires electronic health record systems to meet specific technical criteria, including support for FHIR APIs for modern data exchange, C-CDA for structured document exchange, Direct messaging for secure communication, and standardized clinical terminology like SNOMED CT and LOINC. Your EMR system must also support the United States Core Data for Interoperability (USCDI), which defines minimum data elements including patient demographics, medications, lab results, and clinical notes. These certification standards are mandatory for participating in federal programs and TEFCA.
3. How does the Common Agreement work for health information exchange under TEFCA?
The Common Agreement is the legal and governance contract that establishes privacy practices, security standards, and operational requirements for TEFCA participation. Healthcare organizations connect through a Qualified Health Information Network (QHIN) that has signed the Common Agreement and are capable of enabling full network-to-network exchange with all other TEFCA participants nationwide. Participants must support all permitted exchange purposes, respect patient consent directives, and avoid information blocking practices under the 21st Century Cures Act.
4. What privacy and security standards does TEFCA require for electronic health records?
TEFCA builds on HIPAA requirements and mandates comprehensive technical, administrative, and physical safeguards. Technical safeguards include end-to-end encryption, role-based access controls, comprehensive audit logging, and intrusion detection systems. Administrative safeguards require documented security policies, workforce training, and incident response plans. Organizations must also provide patients with API-based access to their complete health records and implement consent management mechanisms that respect patient preferences while maintaining compliance with federal and state privacy laws.
5. How does TEFCA support public health data exchange and reporting requirements?
TEFCA includes specific provisions for public health interoperability that operate separately from clinical care exchange. Certified health IT systems must support electronic case reporting for notifiable conditions, immunization information system reporting, syndromic surveillance data submission, and electronic vital records reporting. Public health exchanges use specialized technical standards including HL7 v2 messages and web service APIs, with scheduled submission patterns rather than on-demand clinical exchanges. This infrastructure proved critical during the COVID-19 pandemic and builds resilience for future public health emergencies.