November 14, 2014
11 EST/10 CST/9 MST/8 PST
Attending: David Blake and Ross McKinney, Co-Chairs; Mike Champa, Julie Gottlieb, Shilpi Gupta, Betty Harvey, Ray Hutchinson, Nancy Lowitt, Monika Markowitz, Pamela Miller, Heather Pierce, Kelly Reddick, Cory Schmidt, Valerie Smothers, John Sweeney and Radu Vestemean.
1 Review minutes
The minutes were approved as submitted.
2 Review new use cases (FI-12,FI-16, FI-45)
Valerie began the discussion and mentioned the three new use cases.
FI-12 – An individual user assigns a designee who may enter or edit Financial Interest and other relationship or activity information in a central repository on his or her behalf. It assumes the individual user has registered with the central repository and logged into the web or mobile app and the designee has registered with the central repository. David commented that the user should be able to grant different permissions to the designee including reading data, adding data, editing data, and sending disclosures. He agreed the user should be notified. Ross mentioned some institutions don’t allow designees. Valerie added in the data requirements we would include representing the source of the data. If institutions don’t allow that, just having that piece of data could help. FI-12 use case was approved with revisions.
FI-16, A Designee enters or edits data in a web or mobile app to store Financial Interest and other relationship or activity information in a central repository. Mike asked if this takes into account that the designee may be representing many users. Valerie added wording to indicate that the designee would select the individual for whom they are entering data. Monika suggested adding notification when a designee has entered data on behalf of another. Use case FI-16 was approved with additions.
FI-45: An individual user downloads a disclosure of Financial Interest and other relationship or activity information from the central repository. There were no comments. Use case FI-45 was approved.
David commented that nine use cases were approved and asked the group if there were any other cases to include. Cory suggested adding a use case to grant permission for institutions to access data. Valerie asked Heather whether that was in the scope of what is being planned. She added it was not consistent with the current functioning. Ross thought it was important to add. Valerie will add the following use case: The Individual User manages permissions for Requesting organizations to pull a disclosure of a predefined set of data. Cory asked of we should also consider having designee have read only access. Monika asked if this allowed for removal of previously assigned designee. Valerie made the change so user manages permission around their data and keep as two separate things organizations and designees. Valerie will edit FI-12 offline and discuss on the next call.
Mike asked if pull access is granted does that presume the requesting organization can pull a copy of disclosure into an existing system. Valerie thought it would. David agreed it would be important and should be included in the pull use case. Nancy suggested information needs to be dated. Valerie commented that would be included in the data requirements. Nancy clarified this would be at the point when data was accessed. Valerie noted it could be some place in the specification when it was sent to the institution. Nancy commented the institution could gather data and the information could be updated at a later point. Valerie noted appropriate processes would be necessary to address that. David commented it may be a governance issue. The problem is if the institution pulls on an annual basis, or pulls information every month, date stamping would be adequate. David asked Valerie if we had enough information to begin work on data requirements. Valerie commented she thought this was a great set of use cases.
3 Discuss data analysis processIOM Conflict of Interest Disclosure.pdf
Ross began the discussion on what was behind appendix three. The table represented broad categories expected to be included in the harmonized system; however it must be updated periodically. The goal would be to finalize data elements and then work with a list to establish values and definitions. Monika thought it made sense. Ross mentioned the challenge is to make sure information is there so it can be used; this was geared towards the Sunshine Act. The Sunshine Act data elements are a starting point for data elements that might be in the central repository. Ross and David agreed to work with Valerie on Table 1 and report back on the next call. Monika stated the repository does not have to be tied to the Sunshine data elements or definitions; the IOM group proposed the rule but didn’t know how it was going to be used or be effective. It is a good place to start but the categories are either too specific or not specific enough. Heather mentioned using broader terms as needed. Susan added that is a very important point Heather raised. For many reasons the categories in Sunshine are flawed, and overlapping. She supported Heather’s comment to tailor as needed. David noted we are not intending one to one correspondence. Valerie added people often disclose non-financial interests as well. David agreed there was a lot of information that can be pulled out or put into the table and that will be work for the next couple of calls.
Ross, Valerie and David will develop a description of our data requirements.