TEFCA’s Strategic Crossroads: Governance, Payment Levers, and the Real Market Reordering

The federal interoperability push has entered a pivotal new phase, as made clear in a recent interview with Steven Lane, Chief Medical Officer at Health Gorilla, published by HIT Leaders and News. Lane’s remarks signal that TEFCA and the designation of Qualified Health Information Networks are not incremental policy adjustments. They are a redefinition of control, obligation, and value creation in the health data economy.

The introduction of enforceable obligations under TEFCA moves the conversation beyond voluntary networks and soft governance models like Carequality. Lane points directly to how those earlier efforts operated in gray zones, where the purpose of use was often stretched and data sharing lacked meaningful oversight. In contrast, TEFCA demands clarity on intent, scope, and obligations. It requires actors in the health information economy to define their responsibilities and adhere to them under structured audit and compliance mechanisms.

This is not simply about improving technical standards. What is emerging is a new trust architecture, backed by federal authority and payment leverage. TEFCA’s formalization of public health, payment, and healthcare operations as valid purposes of exchange drastically expands the utility of shared data. But the real signal to the market is coming from CMS. Lane’s comments on the pending transition of oversight from ONC to CMS cannot be dismissed as bureaucratic detail. This would position TEFCA directly within the regulatory scope of the country’s largest payer, which is precisely where meaningful behavior change will originate.

ONC can set expectations. CMS can impose consequences. The moment data exchange participation becomes a factor in claims processing, ACO qualification, or quality score adjustment, the market response will be swift. Organizations sitting on the sidelines of TEFCA will find themselves out of network, out of contract, or out of compliance. The incentives are shifting, and the mechanism for enforcing them is no longer theoretical.

Lane also cuts through the cultural stagnation that has long paralyzed interoperability progress. Mistrust, more than technical incapacity, has been the persistent drag on data exchange. Provider groups have resisted giving competitors access to patient records. Health plans have feared transparency that could weaken pricing power. Vendors have built product strategies around restricting flow and monetizing API access. The problem was never the pipes. It was the protectionism.

TEFCA’s enforceable rules and standardized participation obligations start to neutralize that protectionism. It reframes data access as a regulated right, not a strategic asset to be hoarded. The implications are direct: any business model built on data exclusivity needs to evolve, and fast. Lane puts it plainly. Future value will be created not by blocking access, but by delivering services, insights, and outcomes on top of a shared data layer.

The shift toward patient-centered interoperability, which Lane likens to the consumer experience in financial services, is not distant. It is being wired into policy frameworks, technical standards, and most critically, payment contracts. When patients can connect apps and services to a unified data backbone that spans payers, providers, and public health, the competitive advantage will lie with those who can operate across that infrastructure with speed and precision.

The market now faces a decision point. TEFCA will not be optional for long. Once CMS moves from signaling to enforcement, the operational stakes will escalate. Health systems, digital health companies, and payer organizations must invest in readiness now. That means mapping TEFCA workflows, aligning with QHINs, and preparing for a compliance landscape that treats data liquidity as an operational obligation, not an aspirational goal.

This is structural reordering. The window to remain a passive observer is closing. The organizations that understand TEFCA’s function as a payment-tied accountability system will have first-mover advantage in a regulatory environment that is no longer waiting for consensus.