[Openid-specs-heart] Deriving HEART and FHIR from HIPAA

[Adrian Gropper]

*(Apologies for cross-posting in the hope that the groups will communicate
via comments in the shared document <http://bit.ly/HEARTfromHIPAA>. If you
want edit access, please contact me directly)*


Can we expedite a consensus on the HEART profiles directly from HIPAA
rather than just use-cases? The recent release of detailed and up-to-date
guidance from the Office for Civil Rights.
http://www.hhs.gov/hipaa/for-professionals/privacy/guidance/access/index.html

makes this relatively easy. Although it doesn’t answer every question, this
approach, like HIPAA itself, establishes a baseline of functionality for
HEART and can clarify the remaining technical and policy issues. In
addition, deriving the baseline of functionality from HIPAA also helps to
inform the HL7-FHIR standards and their relationship to HEART.

To begin this process, I’ve copied out a few relevant sections of the OCR
guidance document
<http://www.hhs.gov/hipaa/for-professionals/privacy/guidance/access/index.html>
below and have added initial comments that relate to HEART. If we can reach
consensus on interpretation of these comments in HEART, then consensus on
the scope and content of the HEART profiles should be relatively easy.
Furthermore, this approach makes it much easier to inform FHIR, Argonaut,
and SMART to the extent that optionality will be constrained by linking
FHIR to the HIPAA privacy rule.

The initial comments in the Google doc are classified (1-9) according to
what particular aspect of patient-directed interface is being addressed. I
hope we can use the following weeks to resolve any objections to the
interpretations of HIPAA in terms of FHIR and HEART. If we succeed, I
believe the baseline HEART profiles will then become a straightforward
technical exercise. Beyond this baseline, we can then revisit the use-cases
to see what additional features or issues need to be addressed.

Happy New Year and thank you OCR!

Adrian



-- 

Adrian Gropper MD

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