ONC, through the Recognized Coordinating Entity (RCE, i.e., the Sequoia Project), released the TEFCA Exchange Purpose (XP) Implementation SOP for the Public Health sub-XP.

The final SOP was released 8/6/24.

APHL submitted comments on the draft rule to the RCE on 2/12/24.

Summary of SOP

The SOP outlines requirements for implementation to a QHIN for the public health exchange purpose, including to send eCR and ELR data. Public Health is one of six exchange purposes.

 This SOP includes details on the expected response information and the standard way that data should be formatted for a specific purpose (e.g., the data elements, standard format and terminology, ontology, taxonomy, or code set). The SOP is highly technical and includes language to use in initiating nodes for queries.

PHAs are not required to respond to any queries. Only PHAs or their delegates can conduct a QHIN Query or a FHIR query under the T-PH purpose.

For eCR, the HL7 CDA R2 Release 2 is in effect until 1/1/26, then the XP is expected to transition to Release 3.

For ELR, the SOP identifies HL7 V251 ELR Release 1 and the FHIR US Core Laboratory Result Observation Profile.

APHL Feedback Summary

• The SOP should acknowledge the crucial role of intermediaries like AIMS.

• The SOP should clearly designate QHINs to receive public health disclosures.

• The SOP should clarify allowable retention periods for data and the use of the word “should.”

• The SOP should provide clarification on the standards used for ELR and eCR and what data elements are truly required and which standards are referenced for these requirements. APHL further suggests sub-SOPs for these two use cases because requirements are so different.

• Notably the SOP doesn't cover the other public health use cases in HTI-2; these will need to be built out.