ACHDM

American College of Health Data Management

American College of Health Data Management

Payers share data, too! Seven information exchange insights to know

Data exchange options being promoted by TEFCA through QHINs have a variety of implications that payers need to fully understand before signing up.



This article is the fist in a 3-part series. Stay tuned for more. 

Clinical data is a two-way street for payers. These organizations require timely and accurate patient data from their healthcare provider partners. Likewise, payers are mandated by the Centers for Medicare & Medicaid Services to make member data available to external stakeholders via application program interfaces.  

These bidirectional payer connections with mobile apps or to a provider's electronic health records systems and practice management systems include clinical data exchange use cases such as patient access, payer-to-payer data exchange, claims, prior authorization and data sharing to consumers. However, these aren’t the only clinical data exchange functions payers should know.  

This article is the first in a three-part series designed to inform payers about technology options for efficient sharing of members’ data. Payers have options, and the first step is to be informed.  

Know your options as a buyer 

One major challenge to advancing payer interoperability is a lack of understanding of the available options. The Trusted Exchange Framework and Common Agreement (TEFCA), a government-driven initiative, aims to standardize health data exchange nationwide through Qualified Health Information Networks (QHINs).  

While promising, TEFCA adoption presents challenges for payers, such as high infrastructure demands, unclear benefits at this early stage and the evolving nature of its requirements. Payers may find that their current systems aren’t fully equipped to meet TEFCA’s technical and operational demands. 

As an alternative, organizations that represent a large population of providers or private data exchange solutions may provide a more immediate and flexible path to interoperability. These private networks help fill gaps in payer data exchange with lower barriers to entry, fewer infrastructure requirements, and faster implementation timelines. 

Define data sharing requirements 

Payers send and receive member data. On the receipt side, payers request large volumes of patient data for a multitude of business reasons. Seven common use cases noted in a recent College of Healthcare Information Management Executives (CHIME) research report include prior authorization, risk adjustment, care management, quality reporting and submission, claims adjudication and appeals, and payment integrity audits. 

However, securing member data from providers is difficult. Obstacles include multiple and disparate EHRs, varying data formats and other data disparities. These realities often hinder the health plan’s ability to validate, aggregate and standardize member data for application and usability. 

Payers also transmit data. The “send” process entails many of the same challenges listed above and includes use cases such as continuing care, quality reporting, claims processing and compliance with regulatory requirements.  

Payers have made many prior investments in interfaces and exchanges to streamline the sharing of member data. However, these legacy investments often don’t provide a reliable pathway to address new exchange standards and regulatory requirements.  

Insights into health information networks 

Payers must quickly decide where to spend their technology money and resources. QHINs are the newest type of data exchange network to emerge in healthcare. Formally launched in 2023, seven QHINs are currently certified by HHS. 

Their efforts are coordinated by ONC and The Sequoia Project, a Recognized Coordinating Entity (RCE), which is using TEFCA’s framework for the technical exchange of information and the associated business agreement to support data exchange.  

However, in 2024, QHINs expanded their outreach to a variety of new healthcare stakeholders including health plans and payers.  

Seven considerations before signing up 

Payers should pursue efforts to explore news or emerging options, like QHINs. But there are specific obligations, investments and considerations for payers to know. Here are important questions to ask before contracting with a QHIN.  

Strategic and infrastructure alignment 

  • Does TEFCA framework align with your organization's broader goals?

  • Does TEFCA support your focus areas, such as improving HEDIS scores, risk adjustment or advancing value-based care?

  • Will the new partnership complement your current interoperability frameworks, and do you have the infrastructure in place to handle real-time data exchange with FHIR standards and APIs?
  • Data quality and governance 

  • How will TEFCA impact your data quality? Inconsistent or incomplete data could disrupt operations, care management or even risk scores.

  • Participating in TEFCA means trusting QHINs with data governance, which could leave payers with less visibility into critical information flow and even create compliance risks.

  • Do you understand and agree with the QHIN data policies? Some networks de-identify and sell data to life sciences companies and other buyers. Are you informed and comfortable with how your data could be used or sold?
  • Compliance with evolving requirements  

  • Are you ready to meet TEFCA’s evolving requirements? If not, it might be best to wait and avoid unnecessary compliance risks.
  • Operational readiness 

  • Do you have the IT infrastructure needed to meet TEFCA requirements, or will costly upgrades be necessary?

  • If your existing health information exchange partnerships or data exchange deals are efficient, will TEFCA add an unnecessary layer of complexity and cost?
  • Costs and return on investment  

  • What are the upfront and ongoing costs? If payer specific benefits (or use cases) aren’t ready yet, you might be investing too early, especially with TEFCA’s scope still evolving and no clear timeline (or benefits) in sight.
  • Primary source verification 

  • The USCDI standard that TEFCA uses might not meet NCQA requirements or provide the primary source verification payers need to realize business process efficiency.
  • Contractual and legal  

  • The Common Agreement doesn’t allow redlines, which limits flexibility and potentially increases risk.

  • Reciprocity is part of the agreement. If you participate on the network, you are obligated to share information as well as request information. For example, payers are legally obligated to respond for member treatment if anyone queries the QHIN for that member’s records.

  • Use cases will expand and mandatory participation will evolve over time. All participants must respond to purposes of use. Is your organization ready to evolve as TEFCA evolves?
  • Don’t let complexity hinder progress 

    Some companies are building another alternative to the HIE, QHIN and TEFCA options mentioned above. These private data exchange networks offer a lower barrier to entry along with significant benefits to address the immediacy of payer interoperability requirements such as a more consumer-driven way to do business; interoperability expertise to mitigate risk and reduce infrastructure costs; and decades of data sharing knowledge, education and technology to payers. 

    This KLAS Research K2 Collaborative Points of Light Success Story is one example of ways to achieve safe, secure and timely data exchange in healthcare. Steady progress with proven partners, like that achieved by CareFirst BlueCross BlueShield, is a recommended best practice and prudent path for all payers and all service lines.  

    The next article will break down how the FHIR standard revolutionizes electronic data exchange. 

    Anthony Murray, CISSP, is the chief interoperability officer for MRO Corp., a clinical data exchange technology and services provider. 


    This article is the fist in a 3-part series. Stay tuned for more. 

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