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  1. FHIR Specification Feedback
  2. FHIR-45199

Internally inconsistent re: requirements on authentication of patients vs B2B with Patient User permitting Authorization Extension Object assertions

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    • Icon: Change Request Change Request
    • Resolution: Persuasive
    • Icon: Medium Medium
    • Interoperable Digital Identity and Patient Matching (FHIR)
    • current
    • Patient Administration
    • Digital Identity
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      Update NOTE 4.1 one to state:{}

      "However, patient-initiated workflows (for example, “patient request” purpose of use) SHALL always include explicit end-user authorization."

      Examples:

      • Patient authorizes access as in SMART App Launch with clicking a button to authorize the transaction as a mechanism for capturing and carrying consent in authorization code flow
      • Tiered OAuth Use Case - same as nominal SMART App Launch, except user profile data includes sufficiently high IAL1.8 identity assurance and AAL2 authorization assurance
      • B2B Patient User Use Case - include consent, IAL1.8 identity assurance, and AAL2 authentication assurance

      Update first bullet in 4.2 to state:

      "Recognize that the patient already has an account (when a record represents an account)" ... "and allow them authenticate when the credentials are sufficiently strong (IAL1.8/AAL2) and the patient can be matched based on best-practice matching"

      Update language in 1.3 regarding App-Mediated B2B with Patient User to state:

      "... verify the identity of the patient or their authorized rep at IAL1.8 and authenticate them at AAL2 prior to capturing the consent or allowing their access to data."

      instead of:

      "... though the requirements on how data are restricted are beyond this guide’s scope."

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      Update NOTE 4.1 one to state: { } " However, patient-initiated workflows (for example, “patient request” purpose of use) SHALL always include explicit end-user authorization." Examples: Patient authorizes access as in SMART App Launch with clicking a button to authorize the transaction as a mechanism for capturing and carrying consent in authorization code flow Tiered OAuth Use Case - same as nominal SMART App Launch, except user profile data includes sufficiently high IAL1.8 identity assurance and AAL2 authorization assurance B2B Patient User Use Case - include consent, IAL1.8 identity assurance, and AAL2 authentication assurance Update first bullet in 4.2 to state: "Recognize that the patient already has an account (when a record represents an account)" ... "and allow them authenticate when the credentials are sufficiently strong (IAL1.8/AAL2) and the patient can be matched based on best-practice matching" Update language in 1.3 regarding App-Mediated B2B with Patient User to state : "... verify the identity of the patient or their authorized rep at IAL1.8 and authenticate them at AAL2 prior to capturing the consent or allowing their access to data." instead of: "... though the requirements on how data are restricted are beyond this guide’s scope."
    • Clarification
    • Non-substantive
    • current

    Description

      The NOTE in 4.1 states that explicit patient authorization is required for patient access to data, however AEO does not have a way to include that in-line as of this time, so the B2B workflow where an organization's digital certificate is used to authenticate the organization, which then signs a JWT including patient demographics for the patient they wish to request health data about, is at odds with these stipulations in the IG. There are at least 2 more places where the requirement to authenticate the patient directly is reinforced at the beginning of 4.2.

      Related topics include 1) more specific guidance on ID token data and 2) passing that same data in non-OIDC transactions 

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            nussteja Aaron Nusstein
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