Electronic Submission of Medical Documentation (esMD)

Digital Identity and Author of Record

Sub-Workgroups

September 19, 2012

Meeting Etiquette

• Please announce your name each time prior to making comments or suggestions during the call

• Remember: If you are not speaking keep your phone on mute• Do not put your phone on hold – if you need to take a call, hang up

and dial in again when finished with your other call – Hold = Elevator Music = very frustrated speakers and participants

• This meeting, like all of our meetings, is being recorded– Another reason to keep your phone on mute when not speaking!

• Feel free to use the “Chat” or “Q&A” feature for questions or comments

NOTE: This meeting is being recorded and will be posted on the esMD Wiki page after the

meeting

From S&I Framework to Participants:Hi everyone: remember to keep your phone on mute

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Agenda

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Topic Presenter

Announcements and Administrative items Sweta

AoR L1 UC Consensus Results Sweta/Bob

Overview and Introduction of Identity Proofing and Signature Artifact/Delegation of Rights Sub-Workgroup

Bob Dieterle

Announcements

• Schedule this week:

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Day/Time Meeting

Wednesday, September 19 at 10 AM ET

AoR Digital Identity Management SWG

Wednesday, September 19 at 1:00 PM ET

(2 hour session)

• AoR Identity Proofing SWG (1-2 PM)• AoR Signature Artifact/Delegation of Rights SWG (2-3 PM)

Friday, September 21 at 2 PM ET

• AoR SWG Recap (10 Minutes)• Harmonization of UC 1&2

September 2012 Proposed Schedule

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Sun Mon Tue Wed Thu Fri Sat

September 2012*1

2 3 4 5 6 72 PM AoR WG

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9 10 11 12

10 AM - AoR SWG: Digital Identity Management

1 PM - AoR SWG: Identity Proofing

2 PM - AoR SWG: Signature Artifact/Delegation of Rights

13 Leads will

review consensus votes and provide

dispositions

14 2 PM – Joint AoR

and Harmonization

of UC 1&2

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16 17 18 19

10 AM - AoR SWG: Digital Identity Management

---1 PM - AoR SWG: Identity

Proofing2 PM - AoR SWG: Signature

Artifact/Delegation of Rights

20 21 2 PM – Joint AoR

and Harmonization

of UC 1&2

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23 24 25 26

10 AM - AoR SWG: Digital Identity Management

---1 PM - AoR SWG: Identity

Proofing2 PM - AoR SWG: Signature

Artifact/Delegation of Rights

27 28 2 PM – Joint AoR

and Harmonization

of UC 1&2

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30 *This is a tentative schedule and subject to change

AoR L1 UC E2E Review

AoR L1 UC E2E Review AoR L1 UC Consensus

AoR L1 UC Consensus

AoR L1 UC Consensus Voting Results

• 9 Yes Votes• 2 Abstain Votes

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Consensus Voting Round Robin for Committed Members• Yes

– A Yes vote does not necessarily mean that the deliverable is the ideal one from the perspective of the Initiative Member, but that it is better to move forward than to block the deliverable

• Yes with comments– If a Consensus Process attracts significant comments (through Yes with comment votes), it

is expected that the comments be addressed in a future revision of the deliverable.• Formal Objection- with comments

– Indicating a path to address the objection in a way that meets the known concerns of other members of the Community of Interest. "Formal Objection" vote without such comments will be considered Abstain votes.

• Formal Objection – Should a Consensus Process attract even one "Formal Objection" vote with comments from

an Initiative Member, the deliverable must be revised to address the "Formal Objection" vote (unless an exceptional process is declared).

• Abstain (decline to vote)

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Provider EntityPayer Entity

esMD Initiative Overview

PayerProvider

(Individual or Organization)

Contractors / Intermediaries Agent

Payer Internal System

Gat

eway

esMD UC 2: Secure eMDR Transmission

esMD UC 1: Provider Registration

esMD AoR Level 1Digital Identities Bundle Signatures

Certificate Authority

Registration Authority

Provider Directories

AoR -- Phased Scope of Work

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Level 1 – Current Focus

Level 2 - TBD

Level 3 - TBD

Digital signature on aggregated documents

(bundle)

Digital signature to allow traceability of individual

contributions to a document

Digital signature on an individual document

• Focus is on signing a bundle of documents prior to transmission to satisfy an eMDR

• Define requirements for esMD UC 1 and UC 2 Signature Artifacts• May assist with EHR Certification criteria in the future

• Focus is on signing an individual document prior to sending or at the point of creation by providers

• Will inform EHR Certification criteria for signatures on patient documentation

• Focus is on signing documents and individual contributions at the point of creation by providers

• Will inform EHR Certification criteria for one or multiple signatures on patient documentation

Topics for Digital Identities and AoR Workgroup Effort

1. Identity proofing

2. Digital identity management

3. Encryption

4. Digital signatures and artifacts

5. Delegation of Rights

6. Author of Record

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Definitions

Identity (NIST)

A set of attributes that uniquely describe a person within a given context.

Identity (Proposed)

A set of attributes that uniquely describe a person or legal entity within a given context.

Identity Proofing (NIST)

The process by which a CSP and a Registration Authority (RA) collect and verify information about a person for the purpose of issuing credentials to that person.

Identity Proofing (Proposed)

The process by which a CSP and a Registration Authority (RA) collect and verify information about a person or legal entity for the purpose of issuing credentials to that person or legal entity.

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DefinitionsDigital Signature (NIST)

The result of a cryptographic transformation of data that, when properly implemented, provides a mechanism for verifying origin authentication, data integrity and signatory non-repudiation.

Data Integrity (NIST)

Data integrity is a property whereby data has not been altered in an unauthorized manner since it was created, transmitted or stored. Alteration includes the insertion, deletion and substitution of data.

Non-repudiation (NIST)

Non-repudiation is a service that is used to provide assurance of the integrity and origin of data in such a way that the integrity and origin can be verified by a third party. This service prevents an entity from successfully denying involvement in a previous action.

Delegation of Rights

The ability to delegate rights or authority to another to act in a specific capacity on behalf of the grantor of the right. Must include the digital identity of the grantor, the digital identity of the grantee, the rights granted, duration of grant in a format that is usable in transaction and AoR signature events and is verifiable by a third party for non-repudiation purposes.

Initiative Requirement Summary

Initiative Identify Proofing Digital Identity Management

Signing(Exchange Artifact) Encryption Delegation

of RightsAuthor

of Record

DS4P Org/Individual Yes Yes Yes Yes YesDirect Project Address/Server Yes Yes Yes No No

esMD Org/Individual Yes Yes Yes Yes Yes

Healthcare Directories Org/Individual Yes Yes Yes Yes No

LCC Org/Individual Yes Yes Yes Yes YesQuery Health Org/Individual Yes Yes Yes No NoTransitions of

Care Org/Individual Yes Yes Yes Yes Yes

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Mandatory

Optional with consequences

Optional

Future Uses

esMD RequirementsTopics UC1: Registration UC2: eMDR AoR L1 Bundle

Identity Proofing Required Required Required

Digital Credential Management

Required Required Required

Digital Signatures & Signature Artifacts

Required Required Required

Delegation of Rights* Required Required Required

Other

Characteristics of solutionNon-Repudiation

Required Required Required

Characteristics of solutionData Integrity

Required Required Required

* Required if the action of the responsible party is being represented by a third party

Scope for AoR (L1)

In Scope • Identify Proofing as part of Non-Repudiation of

Actor Identity• Digital Credential Management required for

Non-Repudiation Actions (Signing and Delegation), Data Integrity and Encryption

• Digital Signatures and Signature Artifacts for Identity and Non-Repudiation

• Digital Credentials and Artifacts for Non-Repudiation of Delegation as required by UC1 and AoR L1

• Data Integrity requirement actions and artifacts• Encryption of PHI requirements• Interactions with External Provider Directories

Out of Scope• Interactions between:

• Payer and Payer Contractors• Provider and Agent• Payer or Payer Contractor and Gateway

• Transaction level encryption• Document level signatures and individual

contribution signatures• Defining delegation of rights within and between

Providers and other authors

User Story / Workflow

Overall User Story Components

1) All Actors obtain and maintain a non-repudiation digital identity

2) Provider registers for esMD (see UC1)*

3) Payer requests documentation (see UC2)*

4) Provider submits digitally signed document (bundle) to address request by payer

5) Payer validates the digital credentials, signature artifacts and, where appropriate, delegation of rights

*User Stories for UC 1 and 2 have already been defined.

Workgroup will help define bullets 1) and 4)

Sub-Workgroups

1. Identity Proofing

• Wednesday 1-2 pm• Robert Dieterle (Lead)• Proof of identity

requirements• Allowed proofing

processes

2. Digital Credentials

• Wednesday 10-11 am• Debbie Bucci (Lead)• Credential Life Cycle

(issuance, maintenance and revocation)

• Credential uses (Identity, Signing, Proxy, Encryption, Data Integrity)

• Specific use credentials (e.g. Direct)

3. Signing and Delegation

• Wednesday 2-3 pm• Robert Dieterle (Lead)• Signature and

Delegation artifacts• Workflow issues• Delegation process

General Requirements Solution must

be implementable for pilot in Q1/Q2 2013 scale to all providers and payers minimize the operational impact required to establish , maintain

or use a digital identity provide for non-repudiation without resorting to audit logs or

validation of system configuration Standards -- required

NIST 800-63-1 Level 3 (December 2011) NIST 800-57 Part 1 (Revision 3 July 2012) Federal Bridge Certification Authority Medium Level X.509v3+ Digital Certificates

Sub Workgroup: Identity Proofing

Type: Sub workgroup

Goal– Define required process for identity proofing of

healthcare individuals and organizations for esMD

Requirements– NIST SP 800-63-1 Level 3 authentication

(December 2011)– FBCA Medium Level

In-Scope – RA qualifications and certification– Combining RA process with other healthcare identity

proofing (e.g. credentialing)– Policy issues regarding identity proofing

Out-of-Scope– Digital Credential Management– Digital Signatures– Proxy or Delegation

Deliverable: “Summary White Paper”– Assumptions– Statement of Problem– Recommended Solution(s)

• Review of Standards (e.g. NIST, FICAM)• Certification requirements for RAs• Proof of identity requirements for

– Entities– Individuals

• Allowed proofing processes (e.g. as part of credentialing?)

• Frequency of Identity review• Appeals process for denial• Variation based on specific

credentials/use?• Revocation (triggers and process)

– Identify gaps in current policy impacting Identity Proofing

– References

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Identity Proofing (Session 1)• Standards to Review

• NIST (SP 800-63-1)• FBCA Medium Assurance• FICAM• NSTIC• IETF Standards (RFC 3647)• FIPS 201

• Individuals• Should identity proofing of Individuals vary by role? (i.e. Physicians,

allied health, etc.)• Discussion of RA process

• FBCA Medium Level Assurance• Registration Authorities

• Trusted Agents• Notary Public• Use of Hospitals credentialing process

Identity Proofing (Session 1)

• Reference examples• DEA (Electronic Ordering of Controlled Substances)• DirectTrust.org• FDA (Participation in Drug Trials)• State-level efforts for communities in practice (Oregon, Washington, California, Maine)

• I-9 (Validation for Employment)

• SAFE-BioPharma • GSA• E-Prescribing

• Experts to invite to this session (SMEs)• John Hall (Direct)• David Kibbe (DirectTrust and NSTIC)• DEA Representative• Peter Alterman (SAFE-BioPharma)• Federal PKI Representative (Wendy Brown)

Sub Workgroup: Digital Credentials

Goal– Define required process for issuing and managing

digital credentials for esMD

Requirements– NIST SP 800-63-1 Level 3 authentication

(December 2011)– NIST SP 800-57 Part 1 (Revision 3 July 2012) – Federal Bridge Certification Authority (FBCA)

certified Medium Level– Digital Certificates must be X.509 V3+ based– Must be from CA cross-certified with FB– Must provide for non-repudiation as part of the

credentials and artifacts

In-Scope– Digital credential life cycle– Relevant standards– Policy issues regarding Digital Credentials

Out-of-Scope– Identity Proofing– Digital Signatures

Deliverable: “Summary White Paper”– Assumptions– Statement of Problem

– Recommended Solution(s)• Review of standards (e.g. NIST, FBCA,

FICAM)• CA qualifications and list• Issuance process• Credential types and forms• Credential uses (Identity, Signing, Proxy,

Encryption, Data Integrity)• Specific use credentials (e.g. Direct,

DEA)• Maintenance requirements• Revocation process• Trust anchor validation• Non-repudiation assurance

– Identify gaps in current policy impacting Digital Credentials

– References

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Sub Workgroup: Digital Signatures

Goal– Define process, artifacts and standards for

transaction and document bundle digital signatures for esMD

Requirements– Must provide for non-repudiation as part of the

credentials and artifacts– Must ensure data integrity

In-Scope– Use Case 1 and 2 transactions– AoR L1 (Signature binding to aggregated

document bundle)– Signature workflow– Signature artifacts– Identification of relevant standards

Out-of-Scope– AoR L2– AoR L3

Deliverable: “Summary White Paper”– Assumptions– Statement of Problem– Recommended Solution(s)

• Review of Standards (e.g. OASIS, IHE, HL7, …)

• Transaction signature process• Transaction artifacts to meet Use Case

1 and 2 requirements• Document Bundle signature process• Artifacts to meet AoR L1 requirements• Data Integrity requirements• Non-repudiation assurance

– Identify gaps in current policy impacting Digital Signatures

– References

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Digital Signature (Session 1)

• Standards• IHE• OASIS

• XML DigSig

• W3C• FIPS 186 • IETF RFCs• IGTF (Proxy Certificates)

Digital Signatures (Session 1)

• Industry Experts (SMEs)• Verisign/Symantec

• GeoTrust

• DigiCert (Scott Rea)• Adobe• Ping Identity

Digital Signatures(Session 1)

• Industry Examples• DEA (Electronic Ordering of Controlled Substances)• Drug Trials (SAFE-BioPharma)

• Validation of Trust and Non-Repudiation• Level 3 Assurance• IETF Rfc 5280, 2560, 5019, etc.• LTANS (Long-Term Archive and Notary Services)• American Bar Association (IDM Task Force)• EU Qualified Signatures

Sub Workgroup: Delegation and Proxy

Goal– Define credentials, artifacts and process for

Delegation of Rights for esMD

Requirements– Must provide for non-repudiation (NIST definition)

as part of the credentials and artifacts– Revocable

In-Scope– Use Case 1 and AoR L1 Delegation of Rights

requirements– Delegation/Proxy workflow– Delegation/Proxy artifacts– Identification of relevant standards

Out-of-Scope– AoR L2– AoR L3

Deliverable: “Summary White Paper”– Assumptions– Statement of Problem– Recommended Solution(s)

• Review of Standards (e.g. OASIS, IHE, HL7, …)

• Proxy/Delegation Credential/Artifact(s) • Operational consideration for

Proxy/Delegation Creation• Scope/Content of Proxy/Delegation• Revocation of Proxy• Credential Transaction proxy

requirements• Transaction artifacts to meet Use Case

1 requirements• Document Bundle proxy signature

process• Artifacts to meet AoR L1 signature

proxy requirements• Data Integrity requirements• Non-repudiation assurance

– Identify gaps in current policy impacting Delegation & Proxy

– References

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Delegation of Rights (Session 1)

• Relevant Standards• OASIS• SAML Assertions• TJC (Record of Care)• IGTF • Role-Based Access Control (RBAC)• HIPAA Business Associate Agreement (BAA)

• Industry Experts (SMEs)• Dr. Alan Sill (Physicist, Standards Coordinator within the Open

Grid Forum)

Delegation of Rights (Session 1)• Industry Examples

• HIPAA BAA• AFIS (Automated Fingerprint Identification System, FBI)• Daon, Inc. (Biometrics)• Direct HISPs• CLIA requirements for agents or authorized individuals• FEMA First Responder Program• Provider Outpatient and Therapeutics• Power of Attorney/Limited Power of Attorney

• Artifacts for Delegation of Rights• Proxy Certificate• SAML Assertion (binding two certificates for a particular

purpose)