within the use of CDex in US Realm, there should tight alignment with, at a minimum, the uses allowed for health care data noted in [45 CFR 164.506|https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/disclosures-treatment-payment-health-care-operations/index.html].

1. The current set of ActCode values in the value set are not well aligned with existing ActCodes under PurposeOfUse, for example HOPERAT Healthcare Operations is not included. 
2. The set of codes should be expansive to include all descendants of appropriate codes. This is true even with an extensible binding
3. Any missing concepts should be fully named and defined, then added to this part of ActClass
   1. One particularly problematic proposed "temporary code" is operations-nos because this assumes it is proper to have an allowed POU that is not an explicitly defined healthcare operation. Only specified healthcare operations are allowed as noted in 45 CFR 164.506: "Health care operations are certain administrative, financial, legal, and quality improvement activities of a covered entity that are necessary to run its business and to support the core functions of treatment and payment. These activities, which are limited to the activities listed in the definition of “health care operations” at 45 CFR 164.501". For this reason this code should not be allowed.