Through our experience advising clients on the design and implementation of data federation, we have developed a framework outlining the decisions to be made during the process. Based on this framework we are able to guide our clients as they choose the federation services they will offer, design an entitlement model, and assess participating sites’ compatibility with the federation model.
We are able to educate our clients on the potential capabilities and benefits of federation, such as streamlined identity management through a single-sign on system, and risk mitigation and improved regulatory compliance through increased traceability and auditing capabilities. We work with our clients to define the different services that will be provided by the federation network, such as clinical information access, user management, consent and compliance management, and identity and security solutions. We also advise our clients on the development of an effective participation model: a flat participation model gives equal authority to all participating sites, while a classified model distributes powers based on organization type, assurance (risk) level, and/or technical criteria. An appropriate classified participation model decreases risk by ensuring that a large institution with highly developed privacy, security, and compliance practices will have more power over the administration of the system than a small clinic with lesser technological and legal expertise.
Under federation, an entitlement model allows the implementation of access control policies. Access control can be organized according to role or function and organizational affiliation by defining various user types (e.g., doctors, nurses, technical support, and regulatory oversight) and organizations (e.g., hospitals, clinics, health information repositories). We help our clients to define access control, as well as access modalities (viewing vs. updating records) and consent policies. We work with our clients to design appropriate blocking capabilities, that is, controls on access to individual patient records. We can offer legal and technical advice on implementing appropriate levels of blocking, from global (in which access to a particular record is completely blocked), to provider level (in which a record can be accessed only within a particular institution), to named level (in which a record can be accessed only by particular clinicians).
Privacy, Security & Federation Methodology
Prior to the launch of a federation network, it is necessary that participating sites have certain common standards with regard to privacy, security, and technological capabilities; evaluation of these areas is also the basis of a classified participation model. We have designed an assessment framework that evaluates different sites’ practices in these areas, identifies risks to the program, and provides a pathway for the resolution of outstanding issues. We have developed self-assessments for participating sites, the results of which are mapped to a bi-dimensional risk rating system that evaluates the severity of risks and the adequacy of proposed risk mitigation plans. These risk ratings provide an escalation pathway that defines appropriate federation management responses to outstanding risks.