[Openid-specs-heart] HEART 2015-08-05 meeting notes

Thu Aug 6 13:56:12 UTC 2015

A couple of thoughts on this last Josh/John exchange, and the whole thread.

First, in this whole thread, we are assuming US-only in the impact of what
we do. Our charter is international, though many of us work in the US
sphere exclusively. So it's good to be mindful of state-specific
requirements, but it's also good to be mindful of non-US jurisdiction needs
too (which may require needs for extra stringency, extra care with the term
"consent", etc.).

Second, it's true we definitely do rely on the technology layer to achieve
specific effects of "authorization-ish stuff". I can definitely see the
usefulness of distinguishing *gross* vs. *fine* ceremonies at different
stages. It's also important to map what they apply to specifically in each
technology. Here's an attempt:

CeremonyOAuthUMAWhat Alice is authorizingAuthz for client to get scoped
access to use protected resources at resource servergross or fine (if
unchecking is allowed)n/aGranting of access token with scopesRevocation of
access tokengrossn/aRevocation thereofIntro of authz server to resource
servern/agrossUse of UMA protection API, possibly Ts & CsRevocation of
intro of authz server to resource servern/agrossRevocation thereofIntro of
authz server/resource server to clientn/agrossUse of UMA authz API,
possibly Ts & CsRevocation of authz server/resource server to
clientn/agrossRevocation
thereofConfiguring authz server (with policies) to allow or disallow access
to protected resources at resource serversn/afineAccess to protected
resources, revocation of access, time periods of allowable access, possibly
after-the-fact approvals of previously attempted accesses, possibly
requirements for purpose of use once access that can only be enforceable at
a nontechnical layer...

*Eve Maler*ForgeRock Office of the CTO | VP Innovation & Emerging Technology
Cell +1 425.345.6756 | Skype: xmlgrrl | Twitter: @xmlgrrl
Join our ForgeRock.org OpenUMA <http://forgerock.org/openuma/> community!

On Thu, Aug 6, 2015 at 6:28 AM, Moehrke, John (GE Healthcare) <
John.Moehrke at med.ge.com> wrote:

> YES!
>
>
>
> *From:* jmandel at gmail.com [mailto:jmandel at gmail.com] *On Behalf Of *Josh
> Mandel
> *Sent:* Thursday, August 06, 2015 8:19 AM
> *To:* Moehrke, John (GE Healthcare)
> *Cc:* Aaron Seib; Adrian Gropper; Debbie Bucci;
> openid-specs-heart at lists.openid.net
>
> *Subject:* Re: [Openid-specs-heart] HEART 2015-08-05 meeting notes
>
>
>
> As to the division between "gross ceremony" and "finer-grain adjustments",
> I want to suss out whether the following model (which readily applies to
> UMA, though not to vanilla OAuth) is consistent with you have in mind, or
> whether this model is addressing a different question entirely:
>
>
>
> 1. *Gross ceremony* consists of Alice introducing her resource server to
> an authorization server of her choice. For example, she might sign a
> document saying (effectively): "Dear Dr. Jones: please treat my
> authorization server, at https://authz.alice.org
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__authz.alice.org&d=AwMFaQ&c=IV_clAzoPDE253xZdHuilRgztyh_RiV3wUrLrDQYWSI&r=B4hg7NQHul-cxfpT_e9Lh49ujUftqzJ6q17C2t3eI64&m=-FRUOcSi1jbR3LldEvLj8fKY7nzRqZMJm15y378_4LM&s=QvDpF47TIOkp8zRSX9cFJzJ6ZALiPO_M0vsL3dZ-zZg&e=>,
> as representing my wishes for disclosure of my health data. Use the
> decisions that server renders to guide your access control decisions about
> my data." This document is easily comprehensible, could serve as evidence
> in court, etc.
>
>
>
> 2. And then the *finer-grain adjustments* would be made by Alice in
> concert with her authorization server (for example, establishing specific
> policies about who can access her data, and which data, and for what
> purposes, and under what conditions).
>
>
>
> On Thu, Aug 6, 2015 at 9:06 AM, Moehrke, John (GE Healthcare) <
> John.Moehrke at med.ge.com> wrote:
>
> I agree with your proposal for ‘Authorize for Disclosure’ and to
> de-emphasize ‘Consent’… (although this problem with ‘Consent’ is only a USA
> problem)…
>
>
> But I don’t think that a UMA/OAuth ‘token’ will be seen as legitimate
> evidence in a court. It would be quickly shown to be not intelligible by
> the layperson, I can barely read them. Thus it is not evidence of the act
> of ‘authorizing for disclosure’ ceremony.  This is indeed a practice-of-law
> problem that we all hope changes, but I have little hope that it will
> change in the coming 10 years. This is why I want the gross ceremony to be
> a pre-condition, with the UMA/OAuth technology be the fine-grain solution.
> I expect that a gross ceremony can be shown in a court as evidence that all
> parties understood the use of the technology would be used for fine-grain.
> Note that if the courtroom antics change, then this pre-condition simply
> goes away. But by putting it there we enable it to be used, and thus make
> our solution more palatable to the legal folks at those custodian
> organizations that are afraid to release information today.
>
>
>
> John
>
>
>
> *From:* Aaron Seib [mailto:aaron.seib at nate-trust.org]
> *Sent:* Thursday, August 06, 2015 7:58 AM
> *To:* Moehrke, John (GE Healthcare); 'Adrian Gropper'; 'Debbie Bucci'
> *Cc:* openid-specs-heart at lists.openid.net
> *Subject:* RE: [Openid-specs-heart] HEART 2015-08-05 meeting notes
>
>
>
> I tend to agree with John’s recommendation with a friendly amendment.
>
>
>
> We should not mis-use the word consent.  We should use the term –
> authorize for disclosure.
>
>
>
> The primary reason being that the term consent has a lot of baggage and is
> defined in law for Human research protections and authorize for disclosure
> is more accurate to me.  Consent – as pointed out by the Kind Sir from
> Boston (Adrian) to point out – meant something before 2002 that it doesn’t
> mean anymore.
>
>
>
> In my opinion the notion of authorize for disclosure also conveniently
> aligns with my understanding of what ab “UMA/OAuth token” would represent
> on a per transaction basis.
>
>
>
> In court we would expect the entity accused of unauthorized disclosure to
> be able to produce a valid UMA/OAuth token as a sufficient defense from
> mis-representations of trial lawyers.
>
>
>
> Aaron Seib
>
> NATE
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nate-2Dtrust.org_&d=AwMFaQ&c=IV_clAzoPDE253xZdHuilRgztyh_RiV3wUrLrDQYWSI&r=B4hg7NQHul-cxfpT_e9Lh49ujUftqzJ6q17C2t3eI64&m=87vCtxeoEunALdecDlNur8aIU5qcY6YWTAxWw6j34cs&s=PU_01do09mzHBYjfdhFvZCLDAP7Tpxnm1P001w-6AlU&e=>,
> CEO
>
> @CaptBlueButton
>
> (o) 301-540-2311
>
> (m) 301-326-6843
>
>
>
>
>
> *From:* Openid-specs-heart [
> mailto:openid-specs-heart-bounces at lists.openid.net
> <openid-specs-heart-bounces at lists.openid.net>] *On Behalf Of *Moehrke,
> John (GE Healthcare)
> *Sent:* Thursday, August 6, 2015 7:27 AM
> *To:* Adrian Gropper; Debbie Bucci
> *Cc:* openid-specs-heart at lists.openid.net
> *Subject:* Re: [Openid-specs-heart] HEART 2015-08-05 meeting notes
>
>
>
> At the federal level, under HIPAA alone, there is no need for consent for
> purposes of using the data within the Covered Entity for Treatment,
> Payment, and Normal operations.
>
>
>
> BUT, there are plenty of states that require consent… Ignoring reality of
> states regulations is not useful.
>
>
>
> AND, there are some institutions that would rather have a consent that
> authorizes them to share beyond their Covered Entity boundary. Not everyone
> reads HIPAA ‘Treatment’ as an authorization to share with any treating
> provider.
>
>
>
> AND, there are some ‘sensitive’ health topics covered by federal money
> that do come with a requirement for consent for sharing. This was the main
> focus of the DS4P efforts.
>
>
>
> So, let’s not focus on HIPAA alone. Let’s expect that ‘for whatever reason
> an organization wants to have positive evidence that the patient desires
> sharing to happen’ as the trigger to allow it to happen (otherwise deny it
> from happening. This would seem more helpful to the community we are doing
> this work for.
>
>
>
> An important aspect of all of this is how will the organization holding
> the data be able to legally defend that a UMA/OAuth token was valid
> evidence of consent that would hold up in a courtroom… We can’t address
> this in HEART, but it should not slow us down. We again, document this as a
> precondition to our work. One way this is done is that a paper trail is a
> part of the initial setup of a patient engaging with the system.
>
>
>
> John
>
>
>
> *From:* Openid-specs-heart [
> mailto:openid-specs-heart-bounces at lists.openid.net
> <openid-specs-heart-bounces at lists.openid.net>] *On Behalf Of *Adrian
> Gropper
> *Sent:* Wednesday, August 05, 2015 11:49 PM
> *To:* Debbie Bucci
> *Cc:* openid-specs-heart at lists.openid.net
> *Subject:* Re: [Openid-specs-heart] HEART 2015-08-05 meeting notes
>
>
>
> I have never heard the term "simple consent". There's nothing like
> "consent" in the context of data sharing that I can think of. HIPAA removed
> the patient's right of consent in 2002
> https://patientprivacyrights.org/?s=HIPAA+Consent
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__patientprivacyrights.org_-3Fs-3DHIPAA-2BConsent&d=AwMFaQ&c=IV_clAzoPDE253xZdHuilRgztyh_RiV3wUrLrDQYWSI&r=B4hg7NQHul-cxfpT_e9Lh49ujUftqzJ6q17C2t3eI64&m=QPfpP6tNPhNn0uCYFnfBuRqSH5IVEwKw_Jqp3j4NGRQ&s=u1OCcH7ZkX-4jzmNs_eIhVZUi0lQOy0npXd30zYGE8I&e=>
>
> There are consent forms for research but that's not part of the use cases
> we're tackling these days.
>
> Does anyone have an example of consent for clinical data sharing to share
> with us?
>
> Adrian
>
>
>
>
>
> On Thu, Aug 6, 2015 at 12:10 AM, Debbie Bucci <debbucci at gmail.com> wrote:
>
> @Eve - yes I know its client but I'm really hung up on the token
> generation/choices.   Thanks for the tweaks.
>
>
>
> I know we clarified that the release form is NOT consent in one of our
> earlier meetings  but is this (release of information) what I have heard
> others refer to as simple consent?    During this process would access to
> problems/meds/allergies be included in that authorization/consent flow?
> I visualized more than demographics in the conversation.
>
>
>
>
>
>
>
> On Wed, Aug 5, 2015 at 9:21 PM, Justin Richer <jricher at mit.edu> wrote:
>
> Thank you, Adrian, this is a great reference! I think your annotations
> make sense as well, things should map pretty plainly to the OAuth process.
> The tricky part (that we got a start on today) is going to be the scopes
> bits and getting those right.
>
> For an UMA flow, it's also similar, except that the "who can see it" is a
> set of claims instead of the client application.
>
>  -- Justin
>
>
>
> On 8/5/2015 9:12 PM, Adrian Gropper wrote:
>
> I've attached a very typical Release of Information authorization. I've
> annotated the 5 elements common to all such documents that I have ever
> seen. The stuff outside if the rectangles is more or less optional.
>
> This form covers one direction of the EHR-PHR Use Case. It is presented to
> the Custodian (the patient or their designate ) and approved by them by the
> Resource Server and pre-filled with information supplied by the Client, if
> available.
>
> In some cases, the Client information is not available at the time the
> Authorization form is signed. In that case, it will be up to the
> Authorization Server to consider the Client and User information and
> provide the authorization to the Resource Server.
>
> The Resource Server has the final say in all cases and could decide to
> ignore the authorization based on local or jurisdictional policy. This is
> outside the control of the Resource Owner and likely to be out of scope for
> HEART in all use-cases.
>
> This ROI Authorization Form is the only "consent" that I'm aware of in
> clinical IT. Patients are asked to sign other documents, including:
>
> Registration Form, Notice of Privacy Practices, and Treatment Consent but
> none of these has anything to do with sharing of health data (except for
> HIPAA TPO which we will not get into here.)
>
>
>
> Adrian
>
>
>
> On Wed, Aug 5, 2015 at 8:27 PM, jim kragh <kragh65 at gmail.com> wrote:
>
> Thanks for sharing,...  informative and constructive in reaching the
> patient end point.
>
>
>
> May all have a nice evening!
>
>
>
> On Wed, Aug 5, 2015 at 3:26 PM, Debbie Bucci <debbucci at gmail.com> wrote:
>
> Attendees:
>
> Eve Maler
>
> Justin Richer
>
> Josh Mandel
>
> Adrian Gropper
>
> Thomas Sullivan
>
> Debbie Bucci
>
>
>
> We have decided to delineate between mechanical and semantic scope docs.
>
>
>
> For the PCP <-> PHR use case:
>
>
>
> The pre determined choice token confidential token choice and exactly what
> information needs (example: PHR's authorization endpoint)  to be shared in
> advance between the PCP's EHR and Alice's PCP was left out of the
> discussion for now.
>
>
>
> There is one basic mechanical Oauth  generic flow that occurs twice in the
> use case.
>
>
>
> Given the group has generally agreed that the SMART specifications are a
> good place to *start **... *for this particular use case  the only
> semantic FHIR scope that is necessary is the patient/*.read scope that
> grants permission to read any resource for the current patient.
>
>
>
> During the registration process Alice should be able to select at a fine
> grain level which resources she is willing to share with the PHR.   This
> mimic's a specific process - Adrian please provide.  This information will
> be used to generate the access token.
>
>
>
> The one thing left at the end of the discussion is whether the patient
> record is implicit or explicitly stated.  This is a design decision that
> may make a difference as we move towards our next use case in
> which delegation is a factor.
>
>
>
> Corrections/updates appreciated.
>
>
>
>
>
>
>
>
>
>
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>
>
>
>
> --
>
>
>
> Adrian Gropper MD
>
> RESTORE Health Privacy!
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