Sequoia Project publishes new elements for Common Agreement, wants feedback

The Sequoia Project on Monday released its new elements for the Common Agreement, another step in developing its “rules of the road” for trusted health data exchange.

The Elements of the Common Agreement (PDF) are being made available for stakeholder feedback, according to the Sequoia Project, which is ONC’s recognized coordinating entity for the Trusted Exchange Framework and Common Agreement, or TEFCA – which is meant to “provide a single ‘on-ramp‘ to nationwide connectivity,” according to ONC.

The Common Agreement half of that road map – to mix a metaphor – would set the infrastructure model and governing approach for users in different information exchange networks to securely share clinical information with each other – all under commonly agreed-to expectations and rules, regardless of which network they happen to be in.

ONC has tasked Sequoia Project – as the recognized coordinating entity, or RCE – with developing, updating, implementing, and maintaining the Common Agreement.

“The unique role of the non-profit RCE is the ability to bring together stakeholders from across the healthcare and health IT landscape to shape the final Common Agreement and realize our goal to begin sharing in 2022,” said National Coordinator for Health IT Micky Tripathi, in a statement. “The Common Agreement’s overall goal is to establish a floor of universal interoperability across the country.”

Toward that baseline for universal nationwide health data interoperability, and defining legal and technical requirements for secure information sharing, the Common Agreement would provide the governing approach necessary to connect and scale the interconnected Qualified Health Information Networks, or QHINs.

They would meet certain criteria to demonstrate that they can successfully support the requirements of the Common Agreement, which, in its final form, would be a legal agreement signed by each network and the RCE as part of a standardized assessment process. 

The Elements of the Common Agreement – which, again, is still under development, and set to be finalized in early 2022 – are many and varied. Sequoia Project describes them: 

  1. Definitions

  2. Exchange purposes 

  3. Participants and subparticipants

  4. Required Flow-Down Provisions

  5. TEFCA Information and Required Information 

  6. Governing Approach to Exchange Activities Under the Common Agreement

  7. QHIN Designation and Eligibility Criteria 

  8. Cooperation and Nondiscrimination 

  9. RCE Directory Service

  10. Individual Access Services

  11. Privacy and Security 

  12. Special Requirements (including Consent) 

  13. Fees

In the weeks ahead, Sequoia Project will host a series of webinars to offer a forum for discussion the proposed elements and other policy issues around interoperability: change management, confidentiality and accountability, exchange purposes and permitted requests, fees, governance, permitted uses and disclosures, privacy, security and more.

Sequoia Project is also calling on stakeholders to share their feedback during webinars, via email ( or in its online form by October 21, 2021.

“The Sequoia Project, in its role as the RCE, is working diligently with ONC to prepare a draft Common Agreement,” said Mariann Yeager, CEO of the Sequoia Project, in a statement. “Engagement by potential QHINs and other stakeholders in the Common Agreement development process now is essential for successful implementation later.”

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