Do TEFCA’s pricing rules setting up a “biggest‑QHIN‑wins” dynamic?

Here’s the toy model I’m wrestling with:

1. Treatment traffic is by far the largest share of network queries. 2 .Responding QHINs (and their Participants) must answer those queries and cannot bill anyone for the marginal expense of responding.
2. Every QHIN therefore bears (roughly) the same inbound Treatment‑query cost, because (rouchly) every query is broadcast across QHINs.
3. Revenue, however, scales only with your own Participants, since a QHIN can levy fees only on the queries its Participants initiate (or on their annual memberships).

In a two‑QHIN thought experiment, the large QHIN (10k members) turns a healthy profit while the small QHIN (300 members) loses big. To break even, the small node would have to raise its membership or initiation fees ~17x, driving its remaining members straight into the arms of the big node.

The feedback loop suggests we converge on a monopoly or at best a couple of mega‑QHINs.

Questions for TEFCA policy people:

• Is this structural cost‑revenue gap for small QHINs real under the current Treatment rules, or am I missing a counter‑balancing mechanism?
• If real, should TEFCA add some kind of reciprocity payment, cost‑sharing pool, or routing optimization to keep smaller or niche QHINs viable? Or is the thought that charges for non-treatment use cases can somehow balance this out (but… the small nodes would have to charge an arm and a leg).

“I’d appreciate any policy citations, on‑the‑ground experience, or alternative models that either confirm or rebut this “winner‑take‑all” concern.