TEFCA Just Opened the Door Wider on Treatment Exchange
When people think about Treatment exchange under TEFCA®, a lot of them picture health systems querying other health systems. In reality, that's never been the full picture — a health system querying a practicing doctor's office has always been in scope too. What just changed is who else walks through that door. On July 8, 2026, the Recognized Coordinating Entity® (RCE) published Version 2.0 of the Exchange Purpose (XP) Implementation: Treatment SOP, effective August 3, 2026. This one's been in the works for the better part of a year, moving through public comment, several rounds of Caucus feedback, and a Joint Caucus vote in late June.
What actually changed
TEFCA has two flavors of Treatment exchange: the general code (T-TREAT), where a response is optional, and the Required Treatment code (T-TRTMNT), where a response is mandatory. The required-response tier has always been limited to Covered Entities — organizations or providers that electronically transmit health information for standard HIPAA transactions. That part hasn't changed. What's gone is the old requirement to also match a specific named category: hospitals, SNFs, certain clinics, pharmacies, labs, rural health clinics, or one of a defined list of licensed individual provider types. If you were a Covered Entity Health Care Provider but didn't fit one of those named boxes, you didn't get the guaranteed response. Version 2.0 drops the box-matching entirely. Now, any vetted Covered Entity Health Care Provider (or its Delegate) qualifies for the required-response tier — full stop. The SOP also spells out, for the first time in real detail, what counts as "in connection with Treatment" — referrals, provider consultations, prescription fills, medication reconciliation, and care transitions are all named as qualifying uses, alongside clearer lines around what doesn't (like querying after a patient has ended the care relationship).
Why this matters
If you've held off on TEFCA because you assumed the required-response door wasn't open to an organization shaped like yours, it just got wider. More organizations can count on a real-time answer to their own queries — and more Participants and Subparticipants are on the hook to provide one. If you're trying to figure out what that means for your organization, or what connecting through a QHIN like MedAllies would look like, we're happy to talk it through. The full SOP is publicly available on the RCE website — worth a direct read for anyone evaluating what this means for them. https://rce.sequoiaproject.org/tefca-and-rce-resources/
The next RCE public meeting is July 21st at noon; sign up for the series here for the latest updates: https://rce.sequoiaproject.org/events-webinars-and-sessions/
Dianne Koval, RHIA, CCEP, CHPS
Vice President, Operations
Centauri Health Solutions, Inc.