Trusted Network Accreditation Program
The Trusted Network Accreditation Program (TNAP) was developed to directly align with the development of the 21st Century Cures Act required Trusted Exchange Framework and Common Agreement (TEFCA). TNAP, in partnership with HITRUST, seeks to promote interoperability by assuring the security and privacy of trusted networks and the use of enabling technologies in the healthcare ecosystem. The program provides third-party review with accreditation for Trusted Exchange participants, rights management, as well as compliance with new TEFCA regulatory requirements and in partnership with HITRUST CSF® addressing existing security and privacy compliance mandates.
TEFCA will affect a diverse group of industry stakeholders including Qualified Health Information Networks (QHINs), Health Information Exchanges (HIEs), Accountable Care Organizations (ACOs), data registries, labs, providers, payers, vendors and suppliers – and TNAP has been designed to address their needs.
TNAP and HITRUST programs review organizations in the areas of privacy, security, mandated standards and operating rules, and key operational functions. The accreditation program and HITRUST CSF assesses an organization’s ability to comply with privacy and security, HIPAA, HITECH including Omnibus Rule, NIST, ARRA and ACA legislative reform provisions as applicable, as well as technical performance, business processes and resource management. The comprehensive third-party review provides an additional level of confidence for QHINs and other organizations that are under competitive pressures to continually ensure compliance with regulatory requirements, business metrics and best practices.
The Trusted Network Accreditation Program and HITRUST CSF ensures a consistent focus on privacy, security and other core industry requirements including a focus on organizational structure, delineation of third parties and their contractual and agency statuses, PHI data flow, business practices and management of human and physical resources. TNAP criteria is publicly reviewed and enhanced at a minimum of once per year, and more often when necessary due to regulatory requirements, best practices or other significant factors.
Developed through a coalition of industry collaborators, TNAP in conjunction with the HITRUST CSF is:
- Designed to affirm compliance with General Data Protection Regulation (GDPR) requirements
- Vendor and technology agnostic to support blockchain and other enabling technologies
EHNAC follows a structured, transparent and industry-inclusive process that provides for continual improvement. Criteria for the Trusted Network Accreditation Program is available on the EHNAC Criteria Page.
Organizations seeking TNAP Accreditation must provide a copy of the full HITRUST CSF Certification Report as part of the application process. When a HITRUST Assessment is conducted by another Assessor organization, HITRUST CSF Certification must be achieved by the accreditation expiration date in order to be accepted as evidence for EHNAC Accreditation.
TNAP-QHIN – for organizations that provide Health Information Network services as defined by TEFCA. According to the Office of the National Coordinator as defined within the April 2019 released materials “A QHIN’s ability to operate successfully and efficiently is crucial to ensuring all Individuals and providers have appropriate and real-time access to EHI. Therefore, it is critical that QHINs fully understand the breadth and scope of their responsibilities before applying for QHIN Designation. Ensuring their capabilities and compliance to the Common Agreement through testing, rigorous on-boarding, and monitoring will be critical to ensure continuity of services among Participants and Participant Members. Organizations that apply to be a QHIN should do so with an understanding of the infrastructure and personnel necessary to support interoperability at a nationwide scale.”
NOTE: TNAP-QHIN Accreditation doesn’t designate an organization as accepted by the RCE as a QHIN. Approval from the RCE and The Office of the National Coordinator (ONC) is still necessary and entirely separate from the TNAP-QHIN accreditation process.
TNAP-Participant/Participant Member – desire to be recognized as a Participant or as a Participant Member in the ONC trust Exchange Framework. According to the Office of the National Coordinator as defined within the April 2019 released materials, “Participants may include persons or entities that have entered into a contract to participate in a QHIN. Some examples of Participants could include, but are not limited to, a HIN, a health system, a health IT developer, a payer, or a federal agency.” Likewise, ONC suggests the following: “Participant Members may include persons or entities that use the services of a Participant to send and receive EHI. For example, if a QHIN is composed of health information exchanges, the health information exchange would be the Participant, and those who use the health information exchange services, (such as health systems, ambulatory providers, health IT developers, payers, and others) are the Participant Members. Alternatively, a health IT developer could be a direct Participant of a QHIN, in which case, the Participant Members may be the provider practice that uses the health IT developer’s software or services.”
NOTE: TNAP-Participant Accreditation doesn’t designate an organization as accepted by the RCE as a Participant. Approval from the RCE and The Office of the National Coordinator (ONC) is still necessary and entirely separate from the TNAP-QHIN accreditation process.
To begin the application process for Trusted Network Accreditation Program, please email firstname.lastname@example.org or complete the application form. Also, are you looking for hands-on support to help you through the pre-assessment steps, readiness planning process and more? Learn about EHNAC’s Consulting and Advisory Services which have been designed to support the Trusted Network Accreditation Program.
-Janet Rios, CEO, Secure HIT
-Lee Barrett, Executive Director & CEO, EHNAC