Quick answer
Choose an exchange connection by testing the care workflow and counterparties it must serve. Identify whether the SNF connects as a participant or subparticipant, what obligations flow through the agreement and which data can actually be found and used. Network participation alone does not guarantee complete records from every hospital or a successful EHR handoff.
Begin with a missing-information problem
A SNF repeatedly waits for prior medication information from a hospital. A regional HIE offers one connection; the EHR supplier offers another exchange route. Both describe broad network reach. The buying question is whether either route reliably supplies the needed information for the actual resident and staff workflow.
ONC's TEFCA overview distinguishes Qualified Health Information Networks, participants and subparticipants and explains the Common Agreement and technical framework. Some requirements flow to participating organizations. Identify the SNF's actual role and agreements; do not describe every connected facility as a QHIN or assume the same responsibilities apply at every tier.
Map the workflow and the connection path
Write a small set of priority use cases, such as finding prior records for an admission, receiving information after an acute transfer or responding to an authorized request. For each, identify the counterpart, required information, purpose, timing and where staff need the result.
Use this original route comparison:
| Question | Route A evidence | Route B evidence |
|---|---|---|
| Counterparty reach | Verified connection for actual priority partners | Same partner list tested |
| Information availability | Types, dates and known gaps in returned records | Equivalent test population |
| Identity resolution | Matched, ambiguous and no-match behavior | Equivalent identity cases |
| Clinical use | View, import or reconcile path | Same destination workflow |
| Agreements | Role, permitted purposes, obligations and support | Corresponding contract review |
| Operating burden | User administration, monitoring and exceptions | Staff work and recurring costs |
Do not use a network's national organization count as a substitute for the first two rows. A partner may participate through one service but not expose the information needed for the proposed workflow.
Run a bounded exchange trial
Use approved test participants or properly authorized cases under the exchange's procedures. Include a straightforward match, an ambiguous identity, no available records and a returned document with outdated information. Preserve the request, response, timestamps, source and staff action.
In a fictional trial of 20 authorized cases, 15 return some information. Of those, only 11 contain the specific recent document needed for the use case. “75% returned records” and “55% supplied the required document” describe different outcomes. These are illustrative figures, not network performance benchmarks. Explain missingness before extrapolating to all admissions.
An empty result does not prove the resident has no history. Staff need a visible distinction among no match, no available data, unavailable counterpart and technical failure, with an appropriate alternate retrieval path.
Review the participation obligations
Ask for the current agreement and incorporated policies governing the proposed role. Qualified reviewers should examine permitted exchange purposes, responding obligations, privacy/security, identity, audit, incident handling, downstream arrangements and termination. Record version dates and how changes are communicated. A technology demonstration does not establish that a requested use is legally permissible.
Determine whether the SNF's supplier is the participant and the facility a subparticipant, or whether another arrangement applies. Identify who handles certificates or credentials, directories, technical testing and support escalation. The facility should know which organization can resolve a failed exchange rather than opening duplicate tickets without ownership.
Compare total workflow value
Include connection fees, per-site charges, interface work, user training, review time and exception handling. Avoid assigning a financial benefit to every returned document; some may duplicate information already received. Measure the actual time or decision supported by the connection in a local trial.
Acceptance requires a documented path from authorized request to usable information in the resident workflow, with gaps and responsibilities understood. That provides a defensible connection choice even when no route supplies every desired record.
Questions & answers
Does TEFCA participation mean every referral record is available?
No. Verify counterpart participation, available information, matching, permitted purposes and the actual supported exchange path.
Should a SNF always connect directly to a QHIN?
No. Compare available participant and subparticipant routes against workflow, responsibility, support and cost. The right route depends on the actual arrangement.
Primary sources
Use the cited source and its applicable version when making a facility-specific decision. These guides explain operational evaluation methods; they are not individualized clinical, coding, or legal advice.