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“ Jericho / UT Austin Pilot”. Privacy with Dynamic Patient Review. Presented by: David Staggs, JD, CISSP Jericho Systems Corporation. Agenda. Administrative issues Problem statement Specific goal of the pilot Roles available in demonstration of a reference implementation
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“Jericho / UT Austin Pilot” Privacy with Dynamic Patient Review Presented by: David Staggs, JD, CISSP Jericho Systems Corporation
Agenda • Administrative issues • Problem statement • Specific goal of the pilot • Roles available in demonstration of a reference implementation • Notional diagram of expected data flow • Extended data flow for subsequent use • Questions from the Audience • POA&M • Summary
Welcome to the Pilot! • This pilot is a community led pilot • Limited support provided by the ONC • Apurva Dharia (ESAC) • Jeanne Burton (Security Risk Solutions) • Melissa Springer (HHS) • In conjunction with DS4P bi-weekly return of an All Hands meeting • Access to DS4P Wiki, teleconference, and calendar • Meeting times: Tuesdays 11AM (ET) • Dial In: +1-650-479-3208Access code: 662 197 169URL:https://siframework1.webex.com/siframework1/onstage/g.php?t=a&d=662197169
Expectations for the Pilot • Tasked to identify and solve anticipated problems in data segmentation and/or privacy • Tasked to provide user stories that can be used in Agile development of a reference implementation that offers a solution to the problem • Expected to apply current HIT standards to solve anticipated issues in the reference implementation • Tasked to identify resulting issues that may be useful as an update to the DS4P Implementation Guide • Ultimate goal to demonstrate practical a reference implementation and identify any gaps in or extensions to HIT standards
Problem Statement(s) • As the exchange of Personal Health Information (PHI) becomes more commonplace, how can healthcare consumers be confident that their medical information is being appropriately shared? • How can the benefits of the exchange of medical information on demand be realized if healthcare consumers decide not to “opt in?” • Considering the growth of medical identity theft, how can systems releasing PHI protect the physical and financial health of healthcare consumers?
Specific Goals of the Pilot • 1. Define the exchange of HL7 CDA-compliant PCD between a PCD repository and a provider evaluating that includes a report on the outcome of the request back to the healthcare consumer. • 2. Additional goal: use of identifiers that can uniquely identify the healthcare consumer and PCD repository used to report the outcome of the request back to the healthcare consumer by healthcare consumer’s provider and subsequent EHR custodians. • 3. Stretch goal: use of the PCD repository as a proxy allowing direct authentication by the healthcare consumer to the provider, subsequently reducing correlation errors.
Available Roles • Holder of PHI that is participating on the eHealth Exchange • Accepts eHealthExchange compliant request • Retrieves PCD and reports result of request • Synthetic Patent Data is Available • Requester of PHI that is participating on the eHealthExchange • Makes eHealth Exchange compliant request • Repository holding subject’s Patient Consent Directive (PCD) • Transmits PCD to trusted eHealth Exchange requesters • Accepts policy created by subject of shared PHI • Passes HL7-compliant PCD • Displays result of the request transmitted from holder of PHI
Data Flow Expected , = Clinical data A,B = PCD data = reporting Requestor B Patient’s Provider 2nd Requestor PCD Repository Patient
Available Roles, Extended • Secondary requester of PHI that is participating on the eHealthExchange • Makes eHealth Exchange compliant request
Secondary Goals of the Pilot • Exchange and enforce privacy metadata to ensure proper policy-based disclosure and redisclosure of PHI • Accept and display reports from information owners on access control decisions for requests for the patient’s PHI • Create a token passing scheme that facilitates secondary use reporting • Demonstrate dynamic reporting of access to a patient’s PHI and their ability to change their PCD using their PCD central repository
Relationship to DS4P IG • Parts of the IG this pilot will exercise.
Questions? • For example: • How long will this take? • What level of commitment is expected?
Plan of Action • Upon agreement of the participants the POA is • Identify the elements available from previous DS4P pilots • Scope level of effort, decide on extended scenario • Review standards available for returning information on requests • Determine gaps or extensions required in standards • Create XDS.b repository holding PCD • Stand up information holders and requestors • Identify remaining pieces • Document and update IG with results of our experience
Timeline • General Timeline, conditioned on agreement of stakeholders
DS4P References • Use Case: http://wiki.siframework.org/Data+Segmentation+for+Privacy+Use+Cases • Implementation Guide: http://wiki.siframework.org/Data+Segmentation+for+Privacy+IG+Consensus • Pilots Wiki Page: http://wiki.siframework.org/Data+Segmentation+for+Privacy+RI+and+Pilots+Sub-Workgroup
Additional Success Criteria • Exchange and enforcement of privacy metadata (e.g. refrain, POU, sensitivity, confidentiality) • Exchange of PCD location and credential metadata • Exchange of access reporting information to patient • Exchange and enforcement of updated PCD