The inclusion of QHIN Message Delivery Sample Clauses

The inclusion of QHIN Message Delivery we were surprised by the unexpected inclusion of “Push” capabilities into QHIN stack. As an aspiring QHIN, we have been planning to enable valuable push-based workflows within our community, and in fact are expecting to go live with Event Notifications this summer. However, in terms of this TEFCA draft, the potential value is greatly outweighed by two issues: creating too many moving parts too quickly, and lacking clarity and specificity of the target use cases. On the first item, TEFCA is likely asking QHINs to “run before they can walk” by requiring too very different modalities (push and pull) in initial production. For some QHINs who have already had experience with nationwide exchange along these two modalities, it may not create overall network performance or support issues; but for the broader ecosystem of QHINs (especially given the lowered bar for QHIN formation), the current approach may result in tremendous churn (i.e., support requests) both for themselves and to the larger ecosystem of QHINs connected to them, because TEFCA is only going to be as strong as its weakest link. It would be far more prudent to enable push-based capabilities to be brought online after some period of time during which nationwide federated query/pull (QHIN Broadcast Query, QHIN Targeted Query) have stabilized in production. The more significant issue is the lack of specificity in the current TEFCA, which requires “QHIN Message Delivery” while providing less-than-minimal articulation of the Use Cases to be expected. This can lead different stakeholders to have very different expectations of what is going to be delivered (e.g., submission to public health registries vs. physician referrals) by both their QHIN and by TEFCA overall (i.e., all the other QHINs in the community). It also assumes that all “Push” workflows are equivalent, which is simply not true – a workflow and complementary set of services and technologies that are optimized for public health reporting are probably going to have (at best) partial overlap with those needed to create effective referral management. This lack of specificity will need to be addressed by the TEF or by the RCE through the selection of a series of prioritized use cases, else the implementation of TEFCA is going to engender widespread discontent through failed expectations.
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