The Trusted Exchange Framework and Common Agreement (TEFCA) is a nationwide initiative designed to improve how health data is securely shared across the United States. Developed by the Office of the National Coordinator for Health Information Technology (ONC) within the U.S. Department of Health and Human Services, TEFCA establishes a unified legal and technical framework for exchanging electronic health information.
For years, healthcare organizations have struggled with fragmented data systems. Medical records often exist across multiple electronic health record platforms, regional health information exchanges, and provider networks. TEFCA aims to reduce this fragmentation by creating a scalable national infrastructure that enables secure, standards-based interoperability.
As of 2025 and continuing into 2026, TEFCA is actively being implemented. Several Qualified Health Information Networks (QHINs) are operational, and healthcare providers, payors, and public health agencies are aligning their systems with TEFCA’s governance, privacy, and technical requirements. Let us explain what TEFCA is and why it matters for your medical records retrieval needs.
Why TEFCA Was Created
Health information exchange in the United States has historically developed in regional or vendor-specific silos. Even with widespread adoption of electronic health records following the Health Information Technology for Economic and Clinical Health Act (HITECH Act), patient data frequently remains scattered across multiple systems.
This fragmentation can lead to incomplete records when patients receive care from different providers or move between healthcare systems. To address this challenge, the 21st Century Cures Act directed the ONC to develop a trusted exchange framework that would enable nationwide interoperability.
TEFCA was created to achieve three primary goals:
- Establish a universal policy and technical floor for interoperability by standardizing the rules for health data exchange.
- Simplify connectivity between organizations so providers can connect to one network rather than managing numerous individual integrations.
- Improve patient access to health information, ensuring individuals and authorized representatives can securely obtain their medical records.
While TEFCA is meant to improve healthcare, it also benefits law firms and their personal injury clients. As an example, if your client has a home in Rhode Island and one in Florida, and they go to their home in Florida while still receiving treatment for a car accident in Rhode Island, their medical records for that accident would be split between Rhode Island and Florida. If the client fails to mention having gone to Florida while still receiving treatment, you might only retrieve their Rhode Island records and thus, have incomplete records that could significantly reduce the value of their claim. TEFCA’s goals would also make it easier to identify that your client has records in Florida as well that may apply to your case.
What Is TEFCA?
TEFCA includes two core components.
The Trusted Exchange Framework provides a set of principles that guide secure and trusted health information exchange across networks. In other words, it outlines how things should work.
The Common Agreement is the legal contract that defines the responsibilities of participating networks and establishes nationwide rules for data sharing, privacy, and security. This is the contract, or the rules that the participants agree to be legally obligated to do.
Without TEFCA, if your client from Rhode Island goes to a hospital in Florida, the Florida hospital may not be able to easily access their medical history. This may result in repeated tests, duplicated medications, and filling out forms again. With TEFCA, the client’s records are securely shared between systems, so doctors can see their history faster and provider quicker, better care.
What does any of this do for you, the law firm who just needs to retrieve the medical records to evaluate damages and prepare for negotiations? It means that records can be more easily shared electronically, allowing for faster retrieval. It also means that records are more complete, providing stronger documentation of injuries and making it easier to prove causation and damages.
Additionally, it provides data that is standardized and easier to interpret, so you’ll spend less time organizing inconsistent or confusing records and more time building a strong case strategy. Because TEFCA enforces security standards, data-sharing rules, and auditability, it also provides records that are more trusted and easily authenticated, which makes them stronger evidence in court or negotiations. Finally, it reduces overhead and provides a faster turnaround.
Some of these are results that are already being seen, while others are still being rolled out over time.
Qualified Health Information Networks (QHINs)
At the center of TEFCA’s architecture are Qualified Health Information Networks, or QHINs. A QHIN acts as a central data exchange hub that allows organizations to share health information across multiple networks. Instead of building numerous one-to-one integrations, organizations can connect to a single QHIN and gain access to data shared across the broader TEFCA ecosystem.
Each QHIN network generally includes:
- The QHIN, which provides the connectivity infrastructure
- Participants, such as health information exchanges, EHR vendors, and healthcare organizations
- End users, including providers who access and share patient data
QHINs also exchange data directly with one another, creating a nationwide “network of networks” designed to support large-scale interoperability. Organizations seeking QHIN status must meet strict technical and governance requirements established by the RCE.
What this means for you is that TEFCA’s ultimate goal of connecting all networks so that healthcare providers can easily access all of their patient’s medical records across the country can also mean fewer requests and fewer delays when you request medical records, and you’ll be more likely to get all the relevant records.
Principles That Guide TEFCA
TEFCA is built on several core principles designed to support trusted data exchange.
- Standardization: encourages the use of recognized technical standards so systems can communicate consistently.
- Transparency: requires clear documentation of policies, system capabilities, and responsibilities.
- Cooperation and Non-Discrimination: ensures that qualified organizations, including competitors, can participate in the framework.
- Privacy, Security, and Patient Safety: requires strong safeguards to protect sensitive health data.
- Access: ensures individuals and authorized representatives can securely obtain their medical records.
- Data-Driven Accountability: supports responsible data sharing for population health initiatives and public health reporting.
Together, these principles guide the governance and technical structure of TEFCA.
Permitted Uses for Data Exchange
Health information exchanged through TEFCA must fall under specific permitted purposes defined in the Common Agreement.
These include:
- Treatment: enabling providers to coordinate patient care
- Payment: supporting billing and eligibility verification
- Healthcare Operations: such as quality improvement and administrative activities
- Public Health: including surveillance and disease reporting
- Government Benefits Determination: verifying eligibility for public programs
- Individual Access Services (IAS): which allow patients or authorized representatives to obtain medical records
Each permitted purpose includes documentation and authorization requirements to ensure data is used appropriately.
What Do These Principles and Permitted Uses Do for You?
TEFCA’s principles and permitted uses can eliminate the missing records, inconsistent formats, unclear processes, and slow, manual requests out of medical record retrieval. This results in more standardized data and more complete and organized medical records, which allow you to create the timeline, assess the damages, and build a strong case for negotiations more quickly.
Additionally, the permitted uses create more predictable access pathways and, more specifically, a clear legal lane (IAS) for medical record retrieval.
Individual Access Services and the Legal Industry
One of the most impactful TEFCA use cases is Individual Access Services (IAS). This capability allows patients or their authorized representatives to retrieve medical records through TEFCA infrastructure when identity verification requirements are met.
IAS has important implications for industries that depend on timely access to medical records, including law firms handling personal injury or medical malpractice cases, life settlement providers evaluating policies, and clinical research organizations conducting studies.
When participating providers are connected through TEFCA networks, IAS can significantly reduce the time required to retrieve certain medical records, improving efficiency for both healthcare and legal workflows.
While TEFCA is still being implemented across the country and does not yet play a significant role in our medical record retrieval process, IAS does play a role in our EHR process, allowing you to have records delivered to your CMS in a day.
The Role of FHIR in TEFCA
To support modern, API-based interoperability, TEFCA is gradually incorporating the Fast Healthcare Interoperability Resources (FHIR) standard.
FHIR enables structured, machine-readable data exchange between systems and supports real-time access through secure APIs. As adoption expands, healthcare organizations will be able to exchange structured clinical data more efficiently and support new digital health applications.
Because FHIR is still growing but not yet universal, it does not yet have a meaningful direct impact on medical record retrieval for law firms. However, as it is more widely adopted, FHIR has the potential to create a major shift in how law firms retrieve medical records by increasing opportunities for automation, improving accuracy, and providing structured data that makes case analysis easier.
TEFCA and Existing Exchange Networks
TEFCA is not intended to replace existing interoperability frameworks but to provide a national structure that connects them.
For example, Carequality, another framework managed by The Sequoia Project, already facilitates large-scale data exchange across hundreds of thousands of healthcare providers.
TEFCA is designed to unify networks like Carequality under a consistent legal and technical architecture so data can flow more seamlessly across systems.
Challenges in Medical Record Retrieval
While TEFCA represents a major step toward nationwide interoperability, it does not automatically solve all medical record retrieval challenges.
Many providers still operate outside TEFCA networks, particularly smaller facilities and ancillary providers such as imaging centers or long-term care organizations. In addition, exchanged records may not include attachments, imaging files, or physician narratives required for legal or administrative use.
As a result, organizations that rely on complete medical records must often combine interoperability tools with traditional provider-based record requests. This is why law firms like yours often rely on medical record retrieval services like ours.
How Records On Time Supports Interoperability
As interoperability expands, organizations need strategies that account for both the capabilities and the limitations of emerging data exchange frameworks.
Records On Time helps clients navigate this evolving landscape by combining TEFCA awareness with comprehensive medical record retrieval services.
This includes:
- identifying where TEFCA connections may accelerate access
- contacting providers outside interoperability networks
- managing authorization and consent workflows
- tracking missing documentation
- delivering certified, court-ready medical record packages
By integrating interoperability insights with proven retrieval processes, Records On Time helps ensure clients receive complete and reliable records even as the healthcare data ecosystem continues to evolve.
