[KI-LC] A couple of suggested topics for tomorrow's LC leads call
Colin Wallis Kantara
colin at kantarainitiative.org
Sun Aug 23 21:23:47 UTC 2020
If you are having a call tomorrow, a couple of things that have come up
this past week might be worth discussion.
1) John W has a window of free time in the next couple of months or so and
has volunteered to pick up a piece of the mDL Privacy work that he spoke to
on STA's Webinar #3 at the end of June.
The LC might like to consider where that work might be hosted .. a new
ISI-WG project stream? spin up the proposed mDL WG? Other alternatives?
2) The HIAWG has been collecting comments for a submission to ONC on
Kantara's behalf at ONC's request by Sept 4, to go into a report to
Congress on patient identity matching and the notion of a unique health
identifier. I also have a small 10 minute presentation slot on ONC's forum
for the same next Monday Aug 31st and ONC has advised that a few
congresspeople may listen in. I am not proposing to read the written
submission but broadly summarise it, and if I have personal views (I have
not even started the deck), make it clear that they are indeed my own and
not a formal position from Kantara. There are politics associated with
this unique health identifier conundrum and for years the Appropriations
Act has banned any HHS/ONC funding related to the general topic in general
terms. However, the draft 2020 Appropriations Act, indicates a softening of
the position to date. See below..
'Patient Matching.-The general provision limiting funds for actions related
to promulgation or adoption of a standard providing for the assignment of a
unique health identifier does not prohibit efforts to address the growing
problems faced by health systems with patient matching. The agreement
encourages HHS to continue to provide technical assistance to
private-sector-led initiatives to develop a coordinated national strategy
that will promote patient safety by accurately identifying patients to
their health information. Additionally, the agreement directs ONC, in
coordination with other appropriate Federal agencies, to provide a
report to the Committees one year after enactment of this Act studying the
current technological and operational methods that improve identification
of patients. The report shall evaluate the effectiveness of current methods
and recommend actions that increase the likelihood of an accurate match of
patients to their health care data. Such recommendations may or may not
include a standard for a unique patient health identifier. The report shall
include the risks and benefits to privacy and security of patient
Kantara's comments are mostly related to smartphone based Identity
Assurance but include references to UMA and Consent Receipt. But in the
Introduction, current text includes the following..
"Kantara does not believe that patient identity matching is sustainable and
scalable, even if process improvements are made to reduce false matching
rates. Kantara does believe that lifting the prohibition on spending HHS
funds on the notion of a unique patient (ed; change to health) identifier
is appropriate to enable constructive discussion around innovative ways for
patients to choose to leverage an existing identifier they hold together
with processes that ensure its uniqueness but Kantara does not believe a
single national patient identifier should be promulgated. Rather, the
emphasis should be on identity assurance processes relating to the existing
identity and binding of the identity to a credential identifier".
While there is substantive WG support for this, one participant makes the
point that Kantara is straying into political waters that (while it could
engage in being a 501 c6 and therefore able to undertake advocacy) it
should stay clear of, because while we will please some people it will
anger others. Moreover this participant argues that as a matter of policy,
Kantara should never ever take a position that could be perceived as
The LC leads might like to discuss this matter also, to see if there's
consensus on the policy of taking positions that some might perceive as
I've added the applicable WG folks to this email, together with the bridge
details for them.
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