MiHIN, TEFCA, and QHINs: Your Questions Answered
As the national framework for health data exchange continues to evolve, MiHIN is taking important steps to ensure our network is well-positioned with TEFCA (Trusted Exchange Framework and Common Agreement). We know that QHIN (Qualified Health Information Network) decisions can feel complex, and we want to provide clarity about MiHIN’s current role, what it means for our participants, and how we are working to minimize any challenges along the way.
Q&A: MiHIN’s QHIN and TEFCA Participation
Does MiHIN plan to connect to TEFCA as a QHIN?
No. MiHIN will not become a QHIN. Instead, MiHIN is participating in TEFCA as a Participant through a connection with eHealth Exchange (eHX), which serves as the QHIN. MiHIN will connect organizations in our network as sub-participants through eHX.
What if my organization plans to use my EMR as our TEFCA QHIN?
This situation creates some technical and policy challenges. It is important to note that sub-participants have the discretion to choose which use cases they engage in with their QHIN; not all use cases are required to route through the QHIN. Currently, MiHIN does not have an EMR or organizational “flag” in our environment to distinguish data received from one EMR or another. MiHIN is working to create this flag to support filtering of TEFCA queries, allowing for the exclusion of sub-participant data for those who have chosen to use their EMR’s QHIN for each use case.
What risks exist if we use our EMR for TEFCA and MiHIN for other HIE services?
- Partial Data Visibility: Organizations that do not query MiHIN’s QHIN (eHX) or MiHIN directly may miss data that MiHIN aggregates from across the state.
- Patient-Matching Discrepancies: Divergent patient-matching logic between QHINs can lead to incomplete or inaccurate record pulls, impacting clinical decisions.
- Workflow Conflicts: Staff may encounter friction or confusion when navigating data from multiple QHIN sources.
- Loss of Local Context: Clinical staff will need education on what data will be coming from MiHIN and what will be coming from their QHIN.
What documentation is needed to avoid unintended overlap?
MiHIN will ask participating organizations to confirm their understanding of MiHIN’s TEFCA role, acknowledge the risks associated with participating in a separate QHIN, and accept responsibility for any potential overlap or data sharing conflicts until a technical solution is available. In some cases, this may require updates to agreements with MiHIN.
Looking Ahead
MiHIN is actively developing solutions to help distinguish participants and reduce the possibility of overlap between QHIN connections. We are also raising these issues directly with the State of Michigan to ensure alignment at the state level. Our focus remains on supporting our network, maintaining reliable and seamless data exchange, and ensuring that patients and providers benefit from the strongest possible access to health information.
If you have questions about MiHIN’s TEFCA and QHIN participation or how this may impact your organization, please reach out to MiHIN’s Chief Operating Officer, Jaki Porter, at jaki.porter@mihin.org.