June 27, 2023
Micky Tripathi, Ph.D., M.P.P.
National Coordinator for Health Information Technology
Office of the National Coordinator
U.S. Department of Health and Human Services
Re: Letter of Support for The Sequoia Project’s Response to 75P00123R00032 - Trusted Exchange Framework and Common Agreement (TEFCA) - Recognized Coordinating Entity (RCE)
Dear Dr. Tripathi,
CompliancePro Solutions, a wholly owned subsidiary of Genzeon Corporation of Pennsylvania is pleased to offer our support for The Sequoia Project’s continued role as the Recognized Coordinating Entity (RCE) to oversee the onboarding of QHINs, the roll-out of TEFCA, and the realization of the vision made possible through the 21st Century Cures Act.
We strongly encourage the ONC to maintain its current pace and thoughtful approach in implementing the TEFCA framework. The healthcare industry, and patients that rely on exchanged data for the best care and outcomes, cannot afford to skip a beat. The Sequoia Project will provide the continuity necessary to advance TEFCA and improve nationwide interoperability, not only because it is the non-profit 501(c)3, nationwide, neutral convener that successfully launched Carequality, but also due to its unparalleled experience serving as ONC’s TEFCA RCE for the past four years.
The Sequoia Project is ready. It has cultivated working relationships with an initial group of candidate QHINs; developed V1 of the Common Agreement and QHIN Technical Framework; built a strong interoperability team of technical, policy, and legal experts; road-tested mechanisms for public-private stakeholder engagement, outreach, and dissemination; and possesses a proven infrastructure to deliver on ONC’s expectations. The Sequoia Project’s continued role as the RCE is the best way to achieve Congressional and ONC goals for secure, trusted, accessible information sharing among disparate entities nationwide.
CompliancePro Solutions undertakes to create products, content and services that are used by our clients (Covered Entities and Business Associates from large to small) to assist them with their 21st Century Cures Act implementation for interoperability, but really all aspects of the rules that apply to them, especially ones with privacy and security focus. By having a trusted partner such as the Sequoia Project we are able to provide much more detailed and timely information and to incorporate the content from the trails they have blazed in understanding and implementing the various parts of the rules they address. We do not believe there is enough guidance on Cures Act implementation across the entire spectrum of resources available, but we understand these things take time. We are glad that Sequoia Project continues to expand their base.
Our parent company, Genzeon, also builds out interoperability interfaces using FHIR and the other Cures Act standards and likewise is affected as implementation becomes smoother and more commonplace with well-known best practices. Certainly, expansion of the use of TEFCA will happen only with ONC’s continued push, but also with stakeholders and organizations such as the Sequoia Project continuing to be a RCE, to work with QHINs and ONC making connectivity much more easily accomplished, reliable and trustworthy.
Personally, I am concerned about privacy issues with interoperability, as is my nature and background. I find that increasingly formalized connectivity under TEFCA type agreements will be positive for privacy concerns and compliance. Myself and my organization, CompliancePro Solutions are supporters of Sequoia Project being allowed to continue as an RCE.
Please do not hesitate to reach out to me or my organization if you have any questions.
Kelly, McLendon, RHIA, CHPS
Sr VP Compliance and Regulatory Affairs