TEFCA Readiness Checklist: How Healthcare Organizations Can Prepare for 2027 

Healthcare data exchange is expanding beyond individual hospitals, health systems, and regional networks. The Trusted Exchange Framework and Common Agreement (TEFCA) is helping establish a common framework for sharing health information across these networks, making nationwide exchange increasingly practical.

For healthcare organizations, preparing for TEFCA involves understanding how participation works, whether existing EHR and health information exchange systems can support the intended connection, and what changes may be needed to meet applicable technical, security, and operational requirements.

With 2027 approaching, healthcare leaders have an opportunity to assess their current capabilities, identify gaps, and plan the work required for effective participation. In this blog, I cover the key areas to evaluate, the questions to ask EHR vendors and network partners, and the practical steps to build a TEFCA readiness plan.

1. Understand What TEFCA Changes for Your Organization

TEFCA establishes shared rules and a technical framework for participating networks to exchange health information. It aims to reduce the need for organizations to build separate connections with every other network they work with.

The framework supports six exchange purposes:

• Treatment
• Payment
• Health care operations
• Public health
• Government benefits determination
• Individual access services

Each request must use an authorized exchange purpose, and applicable response requirements depend on the purpose and governing rules. TEFCA does not mean that every organization can retrieve every record on demand. Data availability, participation, permitted use, patient matching, and the applicable exchange rules still matter.

For your organization, start with three questions:

1. Which external records do clinicians and staff struggle to obtain today?
2. Which organizations do you exchange information with most often?
3. Where do delays in obtaining outside information affect care coordination, administrative work, or reporting?

Use the answers to identify the workflows that could benefit most from improved exchange. This gives your readiness project a clear purpose before you begin evaluating technical options.

2. Find Your Route Into TEFCA

Most healthcare practices will not need to become Qualified Health Information Networks (QHINs) themselves. QHINs are the designated networks that form the backbone of TEFCA. Eligible organizations can connect as Participants or Subparticipants, either directly through a QHIN or through an existing network or technology provider that connects to one.

The right route depends on your organization, current infrastructure, and exchange needs.

Before selecting a connection pathway, ask your EHR vendor, health information exchange (HIE), or network partner:

• Are you currently connected to TEFCA through a designated QHIN?
• Can our organization participate through your existing connection?
• What agreement, onboarding, and directory requirements apply to us?
• Which exchange purposes can we use through this arrangement?
• What technical changes, fees, and internal resources will we need?
• Who will investigate failed queries, missing records, and connectivity problems?

Do not treat an existing HIE connection or an EHR interoperability feature as proof of TEFCA participation. Ask for confirmation of the actual pathway, applicable agreements, and responsibilities.

The official TEFCA resources provide current participation documents, technical requirements, and implementation guidance.

3. Use This TEFCA Readiness Checklist

Once you understand your likely participation route, assess the systems and processes that will support it. Assign an owner to each area and record the evidence you need before marking it ready.

A. EHR and network connectivity

• Confirm whether your current EHR or HIE supports the intended connection pathway.
• Document which interfaces, APIs, or other exchange capabilities are available.
• Identify dependencies on your vendor, network partner, or internal IT team.
• Establish how your organization will monitor connectivity and resolve failures.

Evidence of readiness: A documented connection plan, named technical owners, and a test plan approved by the relevant partners.

B. Data quality and patient matching

An exchange can deliver information successfully while still creating clinical risk if the record is incomplete, outdated, or associated with the wrong patient.

Review how your systems handle:

• Patient identifiers and demographic changes.
• Duplicate or merged records.
• Medication lists, allergies, and problem lists.
• Encounter dates, document types, and source information.
• Missing fields, conflicting entries, and outdated clinical details.

Test cases should include patients with similar names, changed addresses, incomplete demographic details, and records from multiple facilities. Use approved test data or appropriately protected records.

Evidence of readiness: Documented matching rules, defined escalation procedures, and test results showing how ambiguous or conflicting records are handled.

C. Privacy, security, and access

Review the requirements that apply to your organization’s role under the Common Agreement, the QHIN Technical Framework, relevant operating procedures, HIPAA, and other applicable laws.

Check that your organization has:

• Role-based access controls and appropriate authentication.
• A documented process for approving and removing access.
• Audit trails for relevant information access and exchange.
• Procedures for investigating suspected security incidents.
• Staff training on permitted uses and information handling.
• Clear responsibilities for responding to privacy or security concerns.

Evidence of readiness: Current policies, assigned owners, access-review records, and documented incident-response procedures.

D. Clinical and administrative workflows

Receiving information is only useful when someone can interpret it and take the right next step.

Map how external information will enter your existing workflows. Decide who reviews incoming records, where the information appears in the EHR, how urgent findings are escalated, and how clinicians document their review.

For example, a discharge summary may contain a medication change that conflicts with the medication list already in your EHR. Your workflow should explain who verifies the discrepancy and how the clinical decision is recorded.

Evidence of readiness: An approved workflow, trained staff, and completed end-to-end tests using realistic scenarios.

4. Prepare for FHIR Without Assuming Every Exchange Works the Same Way

FHIR, or Fast Healthcare Interoperability Resources, is a standard for exchanging health information electronically. It supports API-based exchange, allowing systems to request and share structured information through defined interfaces.

TEFCA also supports document-based exchange. The RCE’s guidance describes the use of formats such as C-CDA documents alongside other supported formats, including FHIR resources. The technical approach depends on the relevant TEFCA requirements and implementation pathway.

This distinction matters when reviewing your EHR roadmap.

Do not ask only, “Does our EHR support FHIR?” Ask more specific questions:

• Which FHIR versions and implementation guides does the system support?
• Which data resources can it send and receive?
• Does the intended TEFCA pathway require facilitated FHIR exchange or another technical approach?
• How are authorization, patient matching, errors, and audit information handled?
• What testing has been completed for the specific connection you plan to use?

Also review how your system represents clinical data. A medication name, allergy, or laboratory result may be present in a document but still require careful interpretation before it can be used in another workflow.

The RCE FAQ and current technical documents are better starting points than relying on older summaries of TEFCA requirements.

5. Test the Exchange Before Depending on It

A successful connection test proves that systems can communicate. It does not prove that the information will be usable in a real clinical workflow.

Build a test plan around the situations your organization is most likely to encounter.

Test scenario	What to verify
A patient arrives from another health system	The correct external records can be located and reviewed
Two patients have similar identifying details	The system handles matching uncertainty safely
An outside medication list conflicts with the local chart	Staff can identify and resolve the discrepancy
A document is missing or cannot be retrieved	The failure is visible and has an escalation path
A record contains information from another source	Staff can identify its origin and date
A connection or query fails	The right team can investigate and document the outcome

Include clinicians, health information management staff, compliance personnel, and IT representatives in testing. Each group sees different risks.

For example, IT may confirm that a document arrived successfully, while a clinician identifies that the document is difficult to interpret or appears in the wrong part of the workflow. Both findings matter.

Before moving into routine use, record defects, assign owners, retest fixes, and obtain sign-off from the teams responsible for the workflow.

6. Build a 90-Day Readiness Plan

Your organization does not need to solve every interoperability problem at once. A phased plan can establish priorities and expose dependencies early.

Days 1 to 30: Assess your current position

• Appoint an executive sponsor and a project owner.
• Document your current EHR, HIE, and external exchange arrangements.
• Ask vendors and network partners about their TEFCA connection options.
• Identify high-value clinical and administrative use cases.
• Review current data quality, security, and workflow gaps.

Deliverable: A readiness assessment with a proposed connection pathway, priority use cases, and a list of unresolved questions.

Days 31 to 60: Design the approach

• Confirm the participation pathway and required agreements.
• Review technical dependencies and implementation responsibilities.
• Define patient-matching, data-quality, and access requirements.
• Map the workflows for receiving, reviewing, and acting on outside records.
• Create test cases and agree on acceptance criteria.

Deliverable: An implementation plan with owners, milestones, risks, and measurable acceptance criteria.

Days 61 to 90: Test and prepare for implementation

• Complete the agreed technical and workflow tests.
• Train staff on record review, discrepancy handling, and escalation.
• Document unresolved issues and corrective actions.
• Confirm monitoring, support, and incident-response responsibilities.
• Obtain approval from clinical, technical, and compliance stakeholders.

Deliverable: A documented decision on whether the organization is ready for the next implementation stage, along with any remaining blockers.

These timeframes are a suggested planning structure, not official TEFCA deadlines. Actual implementation depends on the connection pathway, partner availability, technical complexity, and the requirements applicable to your organization.

7. Measure Whether Your Organization Is Ready

Readiness should be demonstrated through evidence rather than a completed checklist alone.

Track measures that show whether information exchange works and supports staff:

• Retrieval success: How often do test requests return the expected records?
• Patient matching: How frequently do test cases require manual review because identity is uncertain?
• Data quality: How often are important fields missing, inconsistent, or difficult to interpret?
• Workflow completion: Can staff find, review, and document external information without unnecessary workarounds?
• Error resolution: How long does it take to investigate and resolve failed queries or data problems?
• Staff preparedness: Can the people responsible explain what to do when records are missing, conflicting, or potentially misidentified?

Set baseline values during testing, then establish targets appropriate to your organization and use case. Do not assume that TEFCA itself prescribes these operational targets.

Review the results with clinical and technical owners. A high retrieval rate will mean little if staff cannot use the returned information safely.

8. Questions to Resolve Before You Commit

Before approving a TEFCA-related project or vendor proposal, make sure leadership has clear answers to these questions:

1. What participation pathway is available to our organization?
2. Which agreements, technical requirements, and exchange purposes apply?
3. What work must our EHR vendor, network partner, and internal team complete?
4. What will implementation, ongoing support, and maintenance cost?
5. How will patient matching and conflicting information be handled?
6. What security, auditing, and incident-response responsibilities apply?
7. What tests and acceptance criteria must be met before go-live?
8. Who owns performance monitoring and issue resolution after launch?

Ask for answers in writing. A general statement that a product is interoperable does not establish that it supports your intended TEFCA use case.

Get Ready Before Your Exchange Needs Grow

TEFCA gives healthcare organizations a shared framework for exchanging health information across networks. Taking advantage of that framework requires preparation across technology, data quality, security, governance, and clinical operations.

Start by confirming your participation options. Then assess your systems, identify the workflows that matter most, test how external information will be handled, and assign responsibility for closing the gaps.

The goal for 2027 is practical: know what your organization needs, understand which requirements apply, and have a tested plan for making exchanged information useful to the people delivering care.

For healthcare technology leaders: Use your next EHR or interoperability review to ask whether your current systems and partners can support your intended TEFCA pathway, what changes are required, and how readiness will be demonstrated before implementation.