This is a quick description of the minimum requirements to turn patient-mediated “transmit” into a usable system for feeding clinical data to a patient’s preferred endpoints. In my blog post last month, I described a small, incremental “trust tweak” asking ONC and CMS to converge on the Blue Button Patient Trust Bundle, so that any patient anywhere has the capability to send data to any app in the bundle.
This proposal builds on that initial tweak. I should be clear that the ideas here aren’t novel: they borrow very clearly from the Blue Button+ Direct implementation guide (which is not part of certification or MU — but aspects of it ought to be).
In a blog post earlier this month, I advocated for ONC and CMS to adopt a grand scheme to improve patient data access through the SMART on FHIR API. Here, I’ll advocate for a very small scheme that ignores some of the big issues, but aims to patch up one of the most broken aspects of today’s system.
The problem: patient-facing “transmit” is broken
Not to mince words: ONC’s certification program and CMS’s attestation program are out of sync on patient access. As a result, patient portals don’t offer reliable “transmit” capabilities.
As architect for SMART Platforms and community lead for the Blue Button REST API, I’m defining open APIs for health data that spark innovation in patient care, consumer empowerment, clinical research. So I was very pleased last month at an invitation to join a newly-formed Federal Advisory Committee called the JASON Task Force, helping ONC respond to the JASON Report (“A Robust Health Data Infrastructure”).
We’re charged with making recommendations to ONC about how to proceed toward building practical, broad-reaching interoperability in Meaningful Use Stage 3 and beyond. Our committee is still meeting and forming recommendations throughout the summer and into the fall, but I wanted to share my initial thoughts on the scope of the problem; where we are today; and how we can make real progress as we move forward.
Our new advisory committee, made up of member organizations with strategic interest in transforming how the healthcare enterprise uses data, will play a critical role in guiding the SMART Platform toward broad adoption and use.
But my subsequent journey into the world of EHR vulnerability reporting left me deeply concerned that our EHR vendors do not have mature reporting systems in place. Patient health data are among the most personal, sensitive aspects of our online presence. They offer an increasingly high-value target for identity theft, blackmail, and ransom. It’s time for EHR vendors to take a page from the playbook of consumer tech companies by instituting the same kinds of security vulnerability reporting programs that are ubiquitous on the consumer Web.
HL7 and EHR Vendors must address security reporting
For background, see my previous blog post describing the details of three security vulnerabilities in C-CDA Display using HL7’s CDA.xsl.
Last month I discovered a set of security vulnerabilities in a well-known commercial EHR product that I’ll pseudonymously call “Friendly Web EHR”. Here’s the story…
The story: discovery and reporting
I was poking around my account in Friendly Web EHR, examining MU2 features like C-CDA display and Direct messaging. I used the “document upload” feature to upload some C-CDAs from SMART’s Sample C-CDA Repository. At the time, I was curious about the user experience. (Specifically, I was bemoaning how clunky the standard XSLT-based C-CDA rendering looks.) I wondered how the C-CDA viewer was embedded into the EHR. Was it by direct DOM insertion? Inline frames? I opened up Chrome Developer Tools to take a look. Continue reading “Case study: security vulnerabilities in C-CDA display”
TL;DR: If you’re using XSLT stylesheets to render C-CDAs in your EHR, make sure you understand the security implications. Otherwise you could be vulnerable to a data breach.
This blog post describes security issues that have affected well-known 2014 Certified EHRs.. Please note that I’ve already shared this information privately with the Web-based EHR vendors I could identify, and I’ve waited until they were able to investigate the issues and (if needed) repair their systems.
Last month I observed a set of security vulnerabilities in XSLT “stylesheets” used to display externally-supplied C-CDA documents in many EHRs. To be specific: the CDA.xsl stylesheet provided by HL7 (which has been adopted by many EHR vendors) can leave EHRs vulnerable to attacks by maliciously-composed documents. Continue reading “Security vulnerabilities in C-CDA Display using CDA.xsl”
InformationWeek Healthcare, February 25, 2014 — Mark Braunstein We’ve seen health informatics booms and busts before — will this one be different?
I’ve been attending HIMSS for decades, and in my view, the exhibit hall is the place to get a true pulse of the industry and the field in general. Over the years we’ve seen booms and busts. I remember HIMSS in my hometown of Atlanta during the heyday of health information exchange in the 90s, when the regional phone companies (remember them?) had huge exhibits touting their entry into the health informatics space…
Healthcare Informatics, February 19, 2014 — David Raths A New HL7 Draft Standard May Boost Web Services Development
Standards development work in healthcare is a challenging, often thankless task, and definitely more of a marathon than a sprint. It isn’t often that a proposed standard garners genuine enthusiasm among people working on interoperability issues, but that is what is happening with HL7 Fast Healthcare Interoperability Resources (FHIR)…
2014 will see wide-scale production and exchange of Consolidated CDA documents among healthcare providers. Indeed, live production of C-CDAs is already underway for anyone using a Meaningful Use 2014 certified EHR. C-CDA documents fuel several aspects of meaningful use, including transitions of care and patient-facing download and transmission.
This impending deluge of documents represents a huge potential for interoperability, but it also presents substantial technical challenges. We forecast these challenges with unusual confidence because of what we learned during the SMART C-CDA Collaborative, an eight-month project conducted with 22 EHR and HIT vendors.