TEFCA and CMS‑Aligned Networks: Complementary Strategies Accelerating Health‑Data Interoperability

Breaking: Federal interoperability Drive Accelerates as TEFCA and CMS-Aligned network Initiatives Advance

the nation’s push to unlock health information across providers, patients, and authorized entities is gaining speed. Two parallel tracks are shaping how electronic health data moves, with TEFCA establishing a nationwide framework and a separate CMS program inviting networks to accelerate interoperability commitments.

Two Tracks, One Goal: Better Access to Health Information

At the core, both efforts aim to help patients receive faster, safer care by making health data easier to access and share. TEFCA, created under the 21st Century Cures Act, sets a common agreement and a single set of nationwide participation rules for network-to-network exchange. CMS, in parallel, invites networks to pledge as “CMS-aligned Networks” under its Health Technology Ecosystem framework to move faster on defined criteria. Participation is voluntary and designed to complement one another rather than compete.

All organizations that have become Qualified Health Information Networks (QHINs) under TEFCA have also pledged to be CMS-Aligned Networks. This overlap highlights a shared goal: streamline data flow while maintaining robust privacy and security protections.

Different Paths to the Same Destination

TEFCA requires a formal governance structure,standardized interoperability policies,and rigorous onboarding to ensure nationwide cross-network exchange. It emphasizes strong commitments to cybersecurity, third-party security reviews, and U.S. ownership considerations, along with precise terms of participation for all network participants.

CMS, by contrast, offers a more agile pathway. Networks identify as CMS-Aligned and conform to the CMS Interoperability Framework to demonstrate progress. While CMS does not mandate a centralized network governance model, it sets expectations, convenes technical working groups, and can remove pledgees that no longer meet criteria. Compliance with HITRUST, HIPAA, and applicable privacy and security laws remains essential.

Key Differences and Common Ground

Both frameworks share core technical expectations, including support for USCDI, HL7 FHIR, and digital identity standards.they also align on the need for timely record location, query capabilities, and treatment-related data sharing.The divergence lies in pace and structure: TEFCA moves through formal governance and national oversight, while CMS-Aligned Networks push forward through continuous testing and rapid learning.

Ultimately, TEFCA aims to lift the entire ecosystem, while CMS-Aligned Networks act as velocity engines that demonstrate concrete milestones. Together, they seek to empower patients and reduce administrative burdens while safeguarding privacy and security.

What This means for Hospitals,Providers,and Patients

For care teams,the combined approach can shorten the time to locate patient records,speed up decision-making,and improve care coordination. For patients, it promises more consistent access to their health information and clearer visibility into who accessed their data and why.

However, advancing interoperability also increases the need for automation, standardized processes, and robust consent management. both tracks emphasize openness around who uses data, when, and for what purpose, and both require adherence to privacy and security standards.

Status Snapshot and Next Steps

TEFCA has been live since late 2023, with QHINs demonstrating cross-network capabilities and ongoing governance updates. CMS’s CMS-Aligned Network pledge program remains open to networks seeking to accelerate interoperability through defined criteria and collaborative work groups. The interplay between these initiatives will influence how quickly interoperable data flows reach real-world use.

Table: Speedy Comparison of TEFCA and CMS-Aligned Network

Aspect	TEFCA	CMS-Aligned Network
Governance	Single, formal nationwide governance framework	Voluntary pledge with active CMS coordination; no centralized governance
Onboarding	Rigorous, regimental onboarding for QHINs	Ongoing connect-a-thon style progress and testing
primary requirement theme	interoperability policies, nationwide connectivity, participation rules	CMS Interoperability Framework criteria and milestones
privacy & security	Extensive compliance for all Participants and Subparticipants	HIPAA, HITRUST, and applicable privacy laws; explicit governance expectations
Scope	Cross-network data exchange at national scale	Accelerated, network-specific milestones with cross-network potential
Data standards	USCDI, HL7 FHIR, digital identity (IAL2/AAL2) guidance	Similar standards, plus practical automation and consent sharing requirements

evergreen insights for the road ahead

• Patient empowerment hinges on obvious data access and consent controls, supported by both TEFCA and CMS frameworks.
• Hospitals and clinics should prepare for increased automation in data requests, consent preferences, and audit trails.
• Security posture will be a differentiator, as ongoing assessments and insurance requirements become standard across networks.

What Do Readers Think?

How should the burden of interoperability be shared among providers, networks, and technology vendors? Which path-TEFCA’s formal governance or CMS’s rapid-iteration pledge-best serves patient care in your community?

Disclaimer: This article is for informational purposes only and does not constitute legal or regulatory advice. For official guidance, consult regulatory authorities and healthcare compliance experts.

Engage and Share Your View

Your experiences shape the rollout of health information interoperability. Share your perspectives in the comments, and tell us which aspects of TEFCA or CMS-Aligned Networks you want explained in plain terms.

For more context, you can explore official materials from the Centers for Medicare & Medicaid Services and related health IT authorities.

External references: CMS Health technology Ecosystem, TEFCA QHINs.

TEFCA Overview: Building a Nationwide Health‑Data Backbone

The Trusted Exchange Framework and Common Agreement (TEFCA) is the ONC‑mandated contract that creates a single “on‑ramp” for providers, payers, and patients to share records across state lines.

• Core components: the Common Agreement, a set of technical standards (FHIR, OAuth 2.0, HL7 v2), and a governance structure that enforces privacy, security, and data‑use policies.
• Milestones: TEFCA Phase 2 entered into effect on 1 Oct 2024, launching the Trusted Exchange Network (TEN) with over 30 million participants by mid‑2025 [1].

CMS‑aligned Networks: The Payer‑Driven Interoperability Engine

CMS‑Aligned Networks are a collection of private‑sector health‑information exchanges (HIEs) that have signed the CMS Interoperability and Patient Access final rule. They are required to:

1. Support real‑time claims and care coordination for medicare‑FFS, Medicaid, and Marketplace plans.
2. Adopt FHIR‑based APIs for patient‑generated health data (PGHD) and e‑prescribing.
3. Maintain certified health‑IT standards (e.g., 5010 X12, NCPDP) for reimbursement.

as of 2025, 12 major CMS‑Aligned Networks serve more than 80 million beneficiaries, covering roughly 60 % of the U.S. population [2].

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How TEFCA and CMS‑Aligned Networks Complement Each Other

TEFCA Strength	CMS‑Aligned Network strength	Combined Impact
Worldwide “on‑ramp” for any ONC‑registered entity	Payer‑centric data flows for claims, eligibility, and value‑based payments	Seamless clinical‑payer data exchange without duplicate contracts
Standardized governance (common consent, breach reporting)	Robust reimbursement workflows (real‑time eligibility, claim status)	Accelerated care‑management and population‑health analytics
Broad stakeholder participation (providers, labs, patients)	Direct integration with CMS payment systems	faster alignment of quality metrics with clinical outcomes

By leveraging TEFCA’s trust framework while routing payer‑specific transactions through CMS‑Aligned Networks, health systems can achieve end‑to‑end interoperability-clinical data meets financial data in a single, secure pathway.

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Key Benefits for Stakeholders

1. Providers

• One‑stop data access: Pull lab results,imaging,and medication histories from any participating HIE via a single FHIR endpoint.
• Reduced administrative burden: Automatic eligibility checks and claim submissions eliminate duplicate entry.

2. Payers

• Improved risk adjustment: Access to longitudinal clinical data enhances modeling accuracy for Medicare Advantage and Medicaid.
• Accelerated value‑based contracts: Real‑time quality metrics flow directly into payment calculations.

3. Patients

• Unified consent management: Patients control data sharing through a single TEFCA consent portal, which cascades to all CMS‑Aligned Networks.
• Better continuity of care: Emergency departments can retrieve full medication lists and allergy data from any state‑wide HIE.

4. Public Health & Researchers

• Nationwide data pooling: TEFCA’s standardized data model combined with payer‑derived outcome data creates a rich research dataset while preserving privacy under the Common agreement.

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Practical Implementation Tips

1. Map Existing APIs to TEFCA Standards

• Convert legacy HL7 v2 messages to FHIR R4 using middleware such as InterSystems IRIS or Redox.
• Ensure oauth 2.0 token exchange aligns with TEFCA’s trust anchor configuration.

2. Integrate Consent Management Early

• Deploy a patient‑centric consent dashboard (e.g., CommonWell Consent Manager) that syncs with the TEFCA consent service.
• Test edge cases: “opt‑out for research but opt‑in for care coordination.”

3. Leverage CMS‑Aligned Network test Environments

• Use the CMS Interoperability Sandbox (available Q3 2024) to validate claim‑status APIs before production rollout.
• Participate in the quarterly Network Interoperability Forum to stay updated on schema changes.

4. establish a Governance Committee

• Include representatives from IT, compliance, clinical leadership, and payer partners.
• Draft a Data Use Agreement (DUA) that references both the TEFCA Common Agreement and CMS‑aligned Network policies.

5. Monitor Performance with Real‑Time Metrics

• track FHIR query latency (< 500 ms target) and API error rates (< 1 %).
• Use the TEFCA Network Health Dashboard to identify bottlenecks across regions.

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Real‑World Case Studies

a. Kaiser permanente’s “Unified Care exchange” (2025)

• Scope: Integrated TEFCA‑enabled HIE with the CMS‑Aligned Network for California Medicaid.
• Outcome: Reduced duplicate lab orders by 32 % and cut claim‑to‑payment cycle time from 12 days to 7 days.
• Key tactics: Adopted a single‑sign‑on (SSO) portal for clinicians, combined with automated eligibility checks via the CMS‑Aligned Network’s API.

b. Rural Health Clinics of Appalachia (RHCA) – interoperability Pilot (2024‑2025)

• Challenge: Limited broadband and fragmented EHRs across 15 clinics.
• Solution: Deployed a cloud‑based FHIR gateway that interfaced with TEFCA’s TEN and the regional CMS‑Aligned Network.
• Result: 86 % of patient encounters had complete medication histories available, leading to a 15 % reduction in adverse drug events.

c. Mayo Clinic’s Population‑Health Dashboard (2025)

• Integration: Merged TEFCA clinical data streams with CMS‑Aligned Network payment outcome data.
• Impact: Identified high‑risk diabetes cohorts across 8 states, enabling targeted care bundles that saved $4.3 M in avoidable hospitalizations.

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Regulatory Landscape & Compliance Checklist

Requirement	TEFCA Alignment	CMS‑Aligned Network Alignment	Action
HIPAA Privacy Rule	Covered under the Common Agreement’s “Data use Policies.”	enforced via payer‑specific Business Associate agreements (BAAs).	Review BAAs for overlap; update UI consent notices.
21st Century Cures Act – Information blocking	TEFCA mandates open APIs; must provide “no‑charge” access.	CMS‑Aligned Networks already comply with “no‑charge” request for eligibility.	Conduct quarterly API access audits.
FHIR Certification	Required for all TEFCA participants (R4).	CMS‑Aligned Networks require FHIR R4 for patient‑generated data.	Obtain ONC Health IT Certification before go‑live.
State‑Specific Data Sharing Laws	TEFCA allows “state add‑ons” in the Common Agreement.	Some CMS‑Aligned Networks have state‑level extensions (e.g., NY Medicaid).	Map state legislation; configure data‑use filters accordingly.

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technology Enablers Driving Interoperability

• FHIR Bulk Data Access – enables high‑volume data pulls for research and analytics, now a required capability for TEFCA participants.
• OAuth 2.0 & openid Connect – Provides secure, token‑based authentication across TEFCA and CMS‑Aligned Network APIs.
• Distributed Ledger (Blockchain) Pilots – Emerging use cases in Maine’s HIE to validate consent provenance across networks.
• AI‑Powered Data Normalization – Tools such as Google Cloud Healthcare API auto‑map legacy codes (ICD‑9 → ICD‑10) to ensure consistency for payer analytics.

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Future outlook: 2026‑2028 Roadmap

1. Full Nationwide TEN Adoption – Goal: 95 % of acute‑care hospitals connected by 2027.
2. Expanded CMS‑Aligned Network coverage – Inclusion of all Medicaid Managed Care Organizations (MCOs) by 2026.
3. Patient‑Owned Data Stores – TEFCA’s upcoming “Personal Health Record (PHR) Bridge” will let individuals push data into the TEN, further enriching payer risk models.
4. Cross‑Network Clinical Decision Support – Real‑time alerts drawn from both TEFCA clinical data and CMS‑Aligned Network cost‑effectiveness metrics.

By aligning the trust framework of TEFCA with the payer‑centric infrastructure of CMS‑aligned Networks,the U.S. health ecosystem is poised to achieve a truly interoperable, patient‑centered data surroundings-accelerating quality care, reducing costs, and unlocking new research horizons.