TEFCA alone is not an interoperability strategy

Health systems are increasingly connecting to TEFCA. In case you haven’t read your TEFCA Cliff Notes in awhile, there are two ways to connect to TEFCA:

1. Become a QHIN, or
2. Become a participant or subparticipant under a QHIN.

While there are currently only 11 designated QHINs recognized by The Sequoia Project, there were over 10,000 TEFCA participants/subparticipants as of late 2025. All of that is to say that TEFCA’s growth is primarily fueled by the addition of participants and subparticipants.

The rapid adoption of TEFCA carries great promise for healthcare interoperability as well as significant operational and trust-related challenges. The requirement that data sources make data accessible in USCDIv3 means better, more consistent data will be available for treatment and individual access requests. Access to more data plus the expansion of profiles targeted to make certain data types easier to work with is a big win in efforts to make clinical data truly actionable.

Trust is a real and powerful player in healthcare interoperability

In addition to the logistical and technical challenges facing TEFCA at the moment, there is perhaps a larger, less tangible problem that looms large: a lack of trust between providers and requestors. The recent lawsuit filed against Health Gorilla and several of its clients underscores why providers have historically been hesitant to share clinical data especially if the use case is not clearly understood or explicitly for treatment.

While we believe that TEFCA’s intentions are good, when you have a network of networks of networks, it’s easy to see how bad actors could slip through the cracks and obtain data to which they should not have access. Who is ensuring that subparticipants of subparticipants meet the requirements intended to protect those connecting to TEFCA?

CMS-Aligned Networks: TEFCA friend or foe?

I’m frequently asked for my take on CMS-Aligned Networks and where they fit into the interoperability picture, especially in regards to TEFCA. Are they in competition with each other? How are they supposed to work together?

Assistant Secretary for Technology Policy Steve Posnack recently provided a great summary of TEFCA and CMS-Aligned Networks in his healthit.gov blog, The Tide and the Speedboats: TEFCA and CMS-Aligned Networks. Here are a couple of big takeaways that are helpful in understanding how TEFCA and CMS-Aligned Networks can work in parallel:

TEFCA and CMS-Aligned Networks are not in competition with each other. In fact, they share the same objectives: “supporting patients, providers, and other authorized entities in securely accessing and exchanging the electronic health information needed to improve care and reduce burden.”

The major difference between TEFCA and CMS-Aligned Networks is in their pace and structure. While TEFCA relies on a centralized and robust network governance structure, CMS-Aligned Networks uses more nimble technical working groups to shape the criteria and measures of success for aligned networks. I think Posnack’s summary of the networks is spot on when he says, “The two approaches are complementary–one provides stability, the other accelerates innovation.”

In short, as data liquidity continues to increase, both TEFCA and CMS-Aligned Networks have a place in helping to shape what healthcare interoperability looks like today and in the future.

TEFCA is just one of many ways to share data: It can be part of your strategy, but it cannot be the end-all, be-all, solve-all.

What providers need to consider about joining TEFCA

Here are a few things I would urge every provider considering joining TEFCA put on their must-do list:

1. Ensure you’re working with your QHIN or on-ramp to TEFCA to understand the data that’s coming in and going out of your system.
2. Understand, in detail, the definition of use cases in play. You need to understand what qualifies as treatment and what does not. Your compliance team should ensure everyone within the organization understands the organizational definition of treatment and how it should be interpreted. If you don’t have a compliance team, someone else within your organization must help as it will impact both the carrot (improved data exchange) and stick (information blocking) when it comes to sharing information.
3. Consider where TEFCA fits into your larger interoperability roadmap. TEFCA is just one of many ways to share data: It can be part of your strategy, but it cannot be the end-all, be-all, solve-all.

Where Moxe fits into all of this

Even in a world where TEFCA is able to move all data needed for treatment, operations, and payment, Moxe can still serve as a firewall that makes sure data is moving appropriately and with the right controls.

We believe in the mission and vision of TEFCA. However, there are still foundational problems to solve before we can expand to all of the various use cases.

Today, the direct exchange of data between payers and providers does not exist through TEFCA. It can through Moxe.

We’ve worked hard to be neutral in our work of connecting payers and providers. We ensure both sides of any data transaction understand where data is going and for what purpose. We safeguard patient data with the utmost care and pride ourselves on our ability to help build trust through close collaboration with providers, technical excellence, and transparency.

Providers who work with Moxe know that only data they approve will get released, and requestors who work with Moxe can more easily earn the trust of providers because those providers know that Moxe is working as a firewall of sorts to help them release the right data, at the right time, to the right place, and nothing more.

Even in a world where TEFCA is able to move all data needed for treatment, operations, and payment, Moxe can still serve as a firewall that makes sure data is moving appropriately and with the right controls.

Will Moxe join TEFCA?

As for how or when we might join TEFCA? Currently, we’re evaluating QHINs and various on-ramps so that when payment and operations use cases go live, we’re prepared to participate.

Today, we get data through our proprietary provider network and enterprise EHR network. Connecting to TEFCA is another way for us to expand our network when payment and operations use cases go live. From a technical perspective, connecting to TEFCA is just like connecting to another data source. We’re prepared and well-positioned to do so, when it makes sense.

To learn more about Moxe’s network of connections, you can download this brief one pager, or reach out to us if you’d like to talk about how Moxe fits into your overall interoperability strategy.