Article

Consent Management System

A path to enhanced Interoperability

Shobhit Saran
VP, CitiusTech

Gati Patel
Sr.HBA, CitiusTech

Guninder Bhatia
Sr. Consultant, CHC

June 23

Insights

Consent management allows patients to control how, when, and by whom their data will be used while ensuring data privacy.
To build a comprehensive consent management system, one needs to address challenges like data aggregation, identity management, data transparency, and compliance with evolving data privacy rules.
Cloud-based deployment, flexibility and scalability, data security, and accessibility are critical features of the consent management system for today’s healthcare organizations.

Interoperability in Healthcare enables health information exchange between patient, provider, and payer to deliver transparent and equitable patient care. However, to enable seamless and secure data exchange across multiple connected systems, it is imperative to have patient consent.

Consent management and patient data privacy should be the major design considerations while enabling patient data access via healthcare APIs to ensure that the patient-protected health information is not being exploited by any unknown system.

Consent management refers to the process and system of collecting and managing patient’s affirmation for using and sharing Patient Protected Health Information (PHI). It also empowers patients to set up privacy preferences to control who, under what conditions, and for what purpose will have access to their protected health information (PHI). It facilitates the dynamic creation, management, and enforcement of consumer, organizational and jurisdictional privacy directives.

The process to enable consent management may appear simple, however, it is challenging to create one such comprehensive solution.

Data Aggregation & Identity Management – As the data is often collected through various channels like websites, mobile apps, etc., mapping the information to respective members is not easy.
Data Transparency – Members are often not aware of how their information is being operated. They should have visibility and should be able to modify the data preferences as and when needed.
Evolving Privacy Rules – It must comply with the ever-evolving regulatory environment. While it is vital for all healthcare organizations to adhere to the privacy regulations and data security requirements stipulated by HIPAA, GDPR and CCPA, the compliance and privacy requirements around sensitive healthcare data are expected to change at breakneck speed. Hence, the consent management system should be flexible enough to adapt to future requirements.

Key features of a consent management system

Different healthcare organizations may have different needs when it comes to a Consent Management System. However, there are a few features that are crucial to today’s healthcare organizations.

1. Cloud-based deployment

Cloud-based consent management has gained more traction substantially, as it allows information to be accessed wherever and whenever needed. The consent management system developed by CitiusTech also leverages cloud storage like GCP, AWS and Azure. This gives it the flexibility to permit members & payers to access/manage records without any geographical constraints.

2. Flexible and scalable

The Consent management system should be flexible enough to support various requirements of healthcare organizations. It would be great if it facilitates an option for both on-site storage and hybrid storage (cloud-based & on-site), so organizations can choose a suitable option.

The Consent Management should be modular enough with a plug-and-play feature that allows a consent management system to work seamlessly with third-party applications & web portals.

3. Data security

Security labeling is yet another crucial feature. To ensure the members’ information and consent records are accessed and stored securely, a consent management system must configure security policies, state-level policies, and patron regulations. It needs to be compliant with the latest healthcare rules and regulations.

4. Accessibility

Consent management should offer comprehensive, integrated and on-the-go consent management to enhance accessibility and easiness. The following are the key considerations to ensure a highly accessible and efficient consent management system.

Offer a comprehensive suite of functionalities to collect, store and enable patients to provide consent to allow or deny access to their healthcare data to another device, provider, application, or organization.
Include an integrated Consent Management Portal for a patient to support “consent declaration” and “tracking & management.”
Enable patients to provide consent on the specific data to be shared with any authorized applications or specific caregivers /payers etc.
Provide Fully integrated and authorized Consent Validation with OAuth2 & OpenID Connect service to access the member specific data

a. Online consent:

In this scenario, it captures one-time member consent over a given period for a list of data attributes and choice of applications.
To provide offline consent, the member needs to log in to the consent management system.
Members can update/revoke the consent as per their requirement.

b. Consent on-the-go:

This is when members download a new third-party health application to access their health data. However, the application does not have existing consent from the member in the consent management system.
The application will prompt for consent by redirecting the member to the consent management system.
Once approved, the requisite health data is accessed.