“Jericho / UT Austin Pilot”

Privacy with Dynamic Patient Review

April 9, 2013

Presented by:David Staggs, JD, CISSP

Jericho Systems Corporation

204/09/2013

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

304/09/2013

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

404/09/2013

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

504/09/2013

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?

604/09/2013

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.

704/09/2013

Available Roles

• Holder of PHI that is participating on the eHealth Exchange– Accepts eHealth Exchange compliant request– Retrieves PCD and reports result of request– Synthetic Patent Data is Available

• Requester of PHI that is participating on the eHealth Exchange– 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

804/09/2013

Data Flow Expected

Patient’s Provider

Patient

PCD Repository

2nd Requestor

Requestor

B

, = Clinical data

A,B =PCD data

= reporting

904/09/2013

Available Roles, Extended

• Secondary requester of PHI that is participating on the eHealth Exchange– Makes eHealth Exchange compliant request

1004/09/2013

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

11

Pilot Team Members

04/09/2013

Name Role Organization

David Staggs Participant Jericho Systems Corporation

Michael Field Participant UT Austin HIT Lab

1204/09/2013

Relationship to DS4P IG

• Parts of the IG this pilot will exercise.

Section of IG Specifics to Pilot Notes

3.2 Pass/enforce metadata Segmentation

12.1 User Story 1 C – (Pull) Enforcement

12.1 Restriction requests 13405(a) update

12.2.1 Accept reporting Secondary use

1304/09/2013

Questions?

• For example:• How long will this take?• What level of commitment is expected?•

14

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

04/09/2013

1504/09/2013

Timeline

• General Timeline, conditioned on agreement of stakeholders

Milestone Target Date Responsible Party

Kick off and Logistics April 2013 Jericho Systems

Basic Infrastructure June 2013 Members

AuthN via Repository August 2013 Members

Reporting Capability October 2013 Members

Complete November 2013 Members

1604/09/2013

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

1704/09/2013

Backup Slides

1804/09/2013

1904/09/2013

2004/09/2013

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