TEFCA is the national framework for exchanging health information, and organizations other than QHINs join it by signing the TEFCA Terms of Participation and connecting through a Qualified Health Information Network (QHIN). This page is for health information exchanges, health IT vendors and provider networks that are joining TEFCA or onboarding their own participants. Integral Healthcare Solutions (IHS) drafts the governance and onboarding procedures your TEFCA terms call for; your counsel and engineers own legal interpretation and technical controls.

Last reviewed: October 2026.

What is TEFCA?

The Recognized Coordinating Entity (RCE) states: “The TEFCA® framework supports nationwide exchange of health information, consistent with Applicable Law.” (RCE FAQs) The Sequoia Project is the RCE: “The Sequoia Project currently serves as RCE under a 5-year contract with ONC awarded in August 2023.” (ASTP/ONC) The RCE's role toward networks: “The RCE designates QHINs and monitors QHINs for compliance with the Common Agreement.” (RCE FAQs)

The governing text is the Common Agreement for Nationwide Health Information Interoperability, listed by the RCE as “Current Version Common Agreement - Version 2.1 Released November 2024” (RCE, Common Agreement), together with the Participant and Subparticipant Terms of Participation. The RCE explains how they relate: “Many elements of Common Agreement Version 2 are incorporated into the Terms of Participation, which must be signed by all TEFCA Participants and Subparticipants without modification.” (RCE FAQs)

Technical requirements sit in a separate document. ASTP/ONC says: “The QHIN Technical Framework (QTF) focuses on the technical components for exchange among QHINs, including patient identity resolution, authentication, and performance measurement. The QTF also includes requirements that flow-down to QHIN participants and subparticipants” (ASTP/ONC).

For this page IHS relied on the RCE and ASTP/ONC public pages. IHS did not open the Terms of Participation text or the RCE Standard Operating Procedures directly, so an engagement starts from your copy of the signed terms.

Who needs it and what triggers it

The buyer is an HIE, a health IT vendor or a provider network that is joining TEFCA or bringing its own participants into exchange. The trigger is a signed network agreement: once your organization signs the Terms of Participation, the obligations in them become operational duties your organization has to run. The RCE describes how non-QHIN entities get in: “To participate in TEFCA exchange, entities other than QHINs must: Be connected into TEFCA exchange through a QHIN. This can be through a direct connection to a QHIN or through a health information network or technology provider that is already connected to a QHIN.” (RCE FAQs)

Every exchange carries a stated purpose. ASTP/ONC: “TEFCA is designed to support exchange for any purpose, but that purpose must be indicated in each request for data.” The Exchange Purposes listed are Treatment, Payment, Health care operations, Public Health, Government benefits determination and Individual access services (ASTP/ONC). Each purpose your organization supports needs a procedure behind it.

How IHS helps

IHS covers governance and operating procedures. The process:

1. Gap assessment of your obligations under your signed network agreement and the Terms of Participation, against the procedures you run today.
2. Responsibility map: each obligation assigned to an owner in your organization.
3. Drafting for your leaders and counsel to approve: governance responsibilities, a participant and subparticipant onboarding procedure, exception and incident-handling procedures, and the evidence records each one produces.
4. Mock review of the onboarding file.
5. Readiness support: drafted responses to findings from your QHIN or network, for your organization to send.

What your organization supplies: the network agreement, your current procedures, your counsel, and your security and engineering staff.

The limit: legal interpretation of the Common Agreement and the Terms of Participation belongs to your counsel, and QTF technical conformance belongs to your engineers. IHS turns their conclusions into procedures and records.

What to have ready

Each item ties to the Common Agreement Version 2.1 framework as described on the RCE and ASTP/ONC pages read October 2, 2026.

1. Your signed Terms of Participation, which participants and subparticipants sign “without modification” (RCE FAQs).
2. Your agreement with the QHIN, or with the health information network or technology provider that connects you to a QHIN (RCE FAQs).
3. A copy of Common Agreement Version 2.1 (RCE).
4. The QTF requirements that flow down to participants and subparticipants, identified by your engineers (ASTP/ONC).
5. A list of the Exchange Purposes your organization will request or respond under (ASTP/ONC).
6. Procedures for indicating the purpose in each request for data (ASTP/ONC).
7. If you support Individual access services, the procedure that handles those requests (ASTP/ONC).
8. Your current onboarding, incident and exception procedures, for the gap assessment.

To walk through this list against your own organization, start with the introductory call.

How it compares

• Becoming a QHIN directly. The RCE states: “Applications to be designated as a Qualified Health Information Network ® are being accepted on a rolling basis.” (RCE) A QHIN is designated and monitored by the RCE (RCE FAQs).
• Joining as a Participant or Subparticipant. Connecting through a QHIN directly or through a network or technology provider already connected to one (RCE FAQs).
• DirectTrust HIE accreditation. A separate, voluntary accreditation; the TEFCA pages we reviewed do not make it a requirement. See DirectTrust HIE accreditation consulting.

What it costs

The RCE does not publish a participant fee on the pages we reviewed. On connection pricing it says: “The Common Agreement prohibits QHIN-to-QHIN fees but does not specify how much QHINs and other TEFCA connectors can charge for their connectivity services.” (RCE FAQs) Fees depend on your connector and scope. IHS scopes each engagement after a free introductory call.

What this is not

• This page is not legal advice, and IHS does not interpret the Common Agreement or Terms of Participation for you; your counsel does.
• IHS does not test or certify technical conformance to the QTF.
• IHS does not deal with the RCE, your QHIN or your network on your behalf. IHS drafts; your organization sends.

Frequently asked questions

What is TEFCA and how does an organization join it?

TEFCA is a framework that, in the RCE's words, supports nationwide exchange of health information, consistent with Applicable Law. Organizations other than QHINs join by connecting through a QHIN, either directly or through a health information network or technology provider already connected to one, and by signing the Terms of Participation.

What are a QHIN, a Participant and a Subparticipant?

QHINs are networks the RCE designates and monitors for compliance with the Common Agreement. Participants and Subparticipants connect through a QHIN, directly or through a connected network or vendor, and sign the Terms of Participation.

What are the TEFCA Terms of Participation, and can we negotiate them?

The RCE says many elements of Common Agreement Version 2 are incorporated into the Terms of Participation. All Participants and Subparticipants must sign them without modification, so the terms themselves are not negotiated.

Which version of the Common Agreement is current?

The RCE lists Common Agreement Version 2.1, released November 2024, as the current version, as of our October 2026 review.

What obligations flow down to us from our QHIN's Common Agreement?

The Terms of Participation carry many Common Agreement elements, and ASTP/ONC says the QHIN Technical Framework includes requirements that flow down to participants and subparticipants. Your counsel reads the legal obligations and your engineers the technical ones; IHS maps them to owners and procedures.

What are the TEFCA Exchange Purposes?

ASTP/ONC lists Treatment, Payment, Health care operations, Public Health, Government benefits determination and Individual access services. TEFCA supports exchange for any purpose, but the purpose must be indicated in each request for data.

What policies do we need in place before going live on TEFCA?

Your signed terms and network agreement set the list, so the work starts there. IHS drafts the governance responsibilities, onboarding procedure, exception and incident handling, and evidence records those terms call for, for your leaders and counsel to approve.

Does joining TEFCA cost money?

The RCE says the Common Agreement prohibits QHIN-to-QHIN fees but does not specify what QHINs and other TEFCA connectors can charge for connectivity. The RCE does not publish a participant fee on the pages we reviewed; ask your connector.