By Stephen Aleksza, PMP | Post-Acute EHR Advisory | In Partnership with HealthTECH
This article is part of our Expert Insights series, where experienced healthcare IT consultants share practical perspectives from real engagements.
Stephen Aleksza, PMP is a post-acute EHR advisor with nearly 30 years of vendor-side experience at Netsmart, Allscripts, and their predecessor platforms, where he led product management and professional services for home health and hospice. He partners with HealthTECH to help hospice, home health, and palliative care organizations navigate EHR selection, optimization, training, and migration.
TEFCA just opened its doors to home health and hospice. That will not get your orders signed.
A home health agency needs a signed physician order before a visit counts, before billing can proceed, and before a surveyor will call the chart clean. The physician who has to sign it might be a mile away. The practice might even run on the same EHR vendor as the agency. Neither helps. The two systems do not talk, so the order goes out the only way it can, by fax. Someone calls to confirm it arrived. Someone calls again three days later because it did not. Multiply that across the open orders on an active census, every week.
That is what an interoperability failure looks like on the ground: a signature stalled in a fax queue while a clock nobody can see keeps ticking. The keynote version of interoperability is measured in records exchanged and networks connected. The floor-level version is measured in hours on hold, waiting to learn whether a piece of paper made it to a provider’s pen.
What the network was built to do
TEFCA deserves credit for what it built. It replaced a patchwork of regional agreements with a single rulebook, and as of June, HHS reports more than a billion records have moved through it. But TEFCA is a network standard. It is not a mandate, and it is not a funding mechanism. It enables exchange for organizations that choose to connect and can afford to, and it does not pay for the work that makes connecting worthwhile.
That gap matters more in post-acute than almost anywhere else, and a physician order shows why. An order is not a record you retrieve with a network query. Someone has to generate it, route it, and get it signed before a billing and compliance clock runs out. That is a workflow problem, and it is not the kind of problem an exchange framework was built to solve.
Why post-acute missed the wave
Acute care and ambulatory medicine had Meaningful Use incentive money pushing them toward connected systems starting in 2009. Home health, hospice, and skilled nursing were left out of that program. No regulatory floor, no funding, and no way to make the investment pay back fast enough on thin margins. Without a push or a pull, the fax stayed the default.
Vendors followed the same math. I spent years on the vendor side of that decision, and R&D goes where the opportunity is largest. Post-acute has generally been the smaller, lower-margin piece of the picture inside companies that also sell to hospitals and health systems. Competitors had little financial reason to agree on a shared format, so for the most part they did not. That is not a conspiracy, just what happens when a small market competes for investment against larger ones under the same roof.
What changed in TEFCA on August 3
A real test has arrived. Version 2.0 of the Treatment Exchange Purpose Implementation SOP took effect on August 3, 2026, and it did more than tighten response rules. Under the old version, a provider had to fit a named category (hospital, SNF, or certain clinics) to qualify for a guaranteed response to a treatment query. That requirement is gone. Any vetted Covered Entity Health Care Provider, home health and hospice agencies included, now qualifies for the required-response tier. If you assumed TEFCA did not apply to you because you never fit one of the old boxes, that assumption expired on August 3.
So the network is finally open to post-acute. What it does for post-acute is a different question. A required response means a hospital’s records can reach your clinician’s screen without a phone call, if your agency is connected and vetted, and if your EHR vendor has done the work to make the connection useful. It does not sign a physician order. That problem is still yours, and it is still a fax machine.
If you want to know where your agency stands, four questions to your EHR vendor will get you most of the way. Are you a QHIN, or aligned with one, and can our agency be vetted for the required-response tier? What will it cost us to be on it? TEFCA itself does not permit fees for required treatment exchange, but your vendor may charge to connect you. Do any of our current integrations already leverage this, and if not, what options are available? And when a query comes back, what actually lands on our clinicians’ screens, in what format, and where? A yes on the first question means little without a good answer to the last.
Measure the change by what reaches a clinician’s screen, not by what shows up in a participation count.
Is your agency planning to connect, or waiting to see whether it pays off for others? I would like to hear which, and what is driving the decision.
From the vendor side
I spent nearly three decades at Netsmart and Allscripts building the home health and hospice platforms that carry these order workflows. If your agency is trying to work out what TEFCA’s expansion means for you, and what to do about the orders it will not touch, I can help you sort the two.
Connect on LinkedIn | Email Stephen | Contact HealthTECH
