D260 Task 1 HIM Environmental Scan Example

When Any Record Can Be Requested From Anywhere: An HIM Environmental Scan of Nationwide Exchange Under the Trusted Exchange Framework and Common Agreement

Student Name

Leavitt School of Health, Western Governors University

D260: Health Information Management Capstone, Task 1

Course Instructor

Month Day, Year

When Any Record Can Be Requested From Anywhere: An HIM Environmental Scan of Nationwide Exchange Under the Trusted Exchange Framework and Common Agreement

The Issue and Its Domain

This environmental scan examines nationwide health information exchange under the Trusted Exchange Framework and Common Agreement (TEFCA). It falls within the HIM domain of information protection: access, use, disclosure, privacy and security, because TEFCA changes who can ask for a patient's records, for what purposes and through what process. It also touches data governance, since information shared nationally is only as good as the data and patient identity behind it.

Why I Chose This Issue

I chose TEFCA for three reasons. First, it is new and still spreading: the framework was published in 2022, and the first qualified health information networks were approved and began exchanging data in late 2023 (Chang et al., 2024). Second, participation is voluntary, so each organization is deciding now whether and how to join, and HIM professionals can influence that decision. Third, in my own work as a coder at a community hospital, I have seen how often outside records arrive by fax or not at all. A framework that makes records available by electronic query will change the daily work of release of information, patient identity management and record governance more than most HIM staff yet realize.

How TEFCA Works

Before TEFCA, organizations exchanged records through many separate networks, each with its own agreements, so a hospital connected to one network often could not reach a clinic on another. TEFCA creates a common set of rules and a single legal agreement for exchange across networks. Organizations called qualified health information networks connect to each other under this common agreement, and hospitals, clinics, health plans and others connect through them as participants and subparticipants. The framework has three stated goals: to set a universal floor of governance, policy and technical requirements for nationwide exchange; to simplify secure connectivity; and to enable individuals to gather their own health information (Chang et al., 2024).

Much TEFCA exchange is query-based. Rather than a hospital deciding to send a record, an authorized user elsewhere asks for information about a patient for a permitted purpose, such as treatment, and systems return it automatically. Mandel et al. (2022) pointed out that the framework allows clinicians and potentially other authorized users, such as health plan staff and public health officials, to query for information about hundreds of millions of patients, and they argued that patients should be able to query for their own data, know when their data are queried and shared, and have a say in that sharing.

Where Adoption Stands

Adoption is growing but uneven. In a 2023 national survey of health information organizations, the regional, state and local exchanges that many hospitals already use, 63% planned to participate in TEFCA, up 7 percentage points since 2019, while 32% did not know whether they would. The most common barrier, reported by 44%, was not yet having a strategic plan for participation (Everson et al., 2024). The same survey found 76 operational health information organizations, down from 89 in 2019, holding more than 600 million patient records, which the authors noted indicates duplication (Everson et al., 2024). For an individual hospital, this means that the path into national exchange depends on decisions its vendors and regional networks are still making.

Implications for HIM Professionals

Release of information and disclosure management. Many requests for continuity of care will arrive and be answered by query instead of by a request letter processed in the HIM office. That is faster for patients, but HIM must decide in advance what is returned. The department will need clear definitions of what information is shared automatically, how disclosures are logged and how staff answer patients who ask who has seen their records.

Sensitive information. Records such as substance use disorder treatment notes, adolescent confidential services and certain behavioral health information carry stricter federal or state protections. Before joining national exchange, HIM must work with IT to tag these data so that they are withheld or shared only when the law allows.

Patient identity. A wrong match in a local system affects one organization; a wrong match in a national query can send one person's record across the country to the wrong patient's clinician. Master patient index quality, long an HIM responsibility, becomes a national concern. Misspelled names and mismatched identifiers are among the most common causes of duplicate records (Just et al., 2016), and every duplicate or overlay in the local index will be exposed to a much larger network.

Individual access. TEFCA is designed to let individuals retrieve their own information through approved applications. HIM will field new questions from patients about apps, identity verification and why a record looks different from the one in the patient portal.

Data quality and governance. Information that leaves the organization by query is read by clinicians who cannot call down the hall to ask what an entry meant. Problem lists, medication lists and allergy records must be accurate and current, which strengthens the case for HIM-led data governance programs.

Risks and Opportunities

The main risks are inappropriate disclosure of sensitive information, patient identity errors carried across networks, uncertainty about which uses beyond treatment an organization should allow, and added workload during implementation. The opportunities are substantial: faster access to outside records for clinicians, fewer faxed and mailed requests for HIM staff, better information for patients and a larger, more visible role for HIM in data governance.

Recommendations for HIM Departments

First, HIM leaders should ask for a seat on their organization's interoperability or TEFCA planning group, since the most common barrier for exchange organizations was the absence of a strategic plan (Everson et al., 2024). Second, they should map which parts of the designated record set would be available through query and write a policy for each category. Third, they should work with IT to tag and segment sensitive information before connecting. Fourth, they should complete a master patient index cleanup and set a monthly duplicate-rate target. Fifth, they should update release of information procedures, the notice of privacy practices where needed and staff training so that HIM staff can answer patients' questions about national exchange and individual access.

Conclusion

TEFCA is moving health information exchange from a patchwork of networks toward a national system in which a record can be requested from almost anywhere. That change will reach every HIM department, whether or not its leaders plan for it. HIM professionals who understand the framework and act now on disclosure policy, sensitive data, patient identity and data quality can make national exchange both safer and more useful.

References

Chang, W., Gabriel, M. H., & Everson, J. (2024). TEFCA awareness and planned participation among U.S. hospitals: 2023 (ASTP Health IT Data Brief No. 72). Office of the Assistant Secretary for Technology Policy.

Everson, J., Chang, W., Patel, V., & Adler-Milstein, J. (2024). The state of health information organizations and plans to participate in the federal exchange framework. Health Affairs Scholar, 2(8), qxae098. https://doi.org/10.1093/haschl/qxae098

Just, B. H., Marc, D., Munns, M., & Sandefer, R. (2016). Why patient matching is a challenge: Research on master patient index (MPI) data discrepancies in key identifying fields. Perspectives in Health Information Management, 13(Spring), 1e.

Mandel, J. C., Pollak, J. P., & Mandl, K. D. (2022). The patient role in a federal national-scale health information exchange. Journal of Medical Internet Research, 24(11), e41750. https://doi.org/10.2196/41750