John Moehrke XACML Consent Example
0.1.0 - ci-build International flag

John Moehrke XACML Consent Example, published by John Moehrke (Moehrke Research LLC). This guide is not an authorized publication; it is the continuous build for version 0.1.0 built by the FHIR (HL7® FHIR® Standard) CI Build. This version is based on the current content of https://github.com/JohnMoehrke/xacml-consent/ and changes regularly. See the Directory of published versions

Artifacts Summary

This page provides a list of the FHIR artifacts defined as part of this implementation guide.

Structures: Resource Profiles

These define constraints on FHIR resources for systems conforming to this implementation guide.

FHIR Consent with XACML Policies

A FHIR Consent resource that references XACML policies for access control, without including any rules directly in the Consent. Therefore, it does not include any provisions directly within the Consent. The actual access rules are defined in the referenced XACML policy documents.

Terminology: Value Sets

These define sets of codes used by systems conforming to this implementation guide.

AB352 Segmentation Tags

ValueSet of security labels used to segment AB352-sensitive health information in meta.security.

Abortion-Related Health Topics (Health Net California)

Health Net explains and references 500073-Abortion-DX-Code-List.pdf file primarily within its Provider Library and through Provider Bulletins related to legislative compliance. The specific explanation is found in the context of Assembly Bill (AB) 352, which mandates the segregation and protection of sensitive health data.

Where the Explanation is Located:

  1. Provider Bulletin 24-351 (New Laws Help Safeguard Privacy): Health Net (and its affiliate Wellcare) issued this bulletin to explain the requirements of AB 352. The bulletin explicitly identifies abortion and abortion-related services as "Sensitive Services" that must be:
    • Segregated from the rest of the patient's medical record.
    • Excluded from automatic sharing with the California Data Exchange Framework (DxF).
    • Protected from out-of-state subpoenas or investigations.
    • Reference: Wellcare/Health Net Bulletin 24-351
  2. Health Net Provider Library - Pregnancy Termination Section: The website hosts a dedicated page for pregnancy termination benefits. It explains that to comply with California laws (specifically SB 245 for cost-sharing and AB 352 for privacy), providers must use specific diagnosis codes. The 500073 PDF serves as the technical master list for these required codes.
  3. The PDF Itself: The document title, ICD-10-CM Codes for Abortion-Related Services, is the direct label Health Net uses on its search results and directory pages to explain what the file contains. It lists codes ranging from O00 (Ectopic pregnancy) to Z33.2 (Encounter for elective termination).

How Health Net Directs Providers to Use This File:

According to the site's AB 352 guidance, Health Net recommends that IT and Billing departments download this PDF and use the listed codes to create firewalls in EHR systems. If a patient's record contains any code found in 500073-Abortion-DX-Code-List.pdf, the system should automatically:

  • Block that data from being sent to out-of-state entities.
  • Prevent the data from being discovered in automated health information exchanges.

Direct Link to the Document: 500073-Abortion-DX-Code-List.pdf

Note: This list may not be all-inclusive and is subject to change.

Contraception-Related Health Topics

Clinical concepts related to contraception drawn from LOINC, SNOMED CT, and ICD-10-CM. Intended for segmentation of sensitive reproductive health information under AB352.

This ValueSet does not include code recommendations from Health Net California. Health Net California does not have a single source document for contraception-related codes similar to their abortion-related code list. Instead, Health Net references multiple sources, including the DHCS Family PACT Code List, within various policy documents.

  • Health Net Bulletin 24-351: New Laws Help Safeguard Privacy (View Link)
  • Health Net Medi-Cal Provider Manual (Chapter 4): Sensitive Services section (Link to Manuals)
  • Family PACT Policies: Health Net adopts the DHCS Family PACT Code List as their baseline for identifying what constitutes a contraceptive service.
Gender-Affirming Care Codes (Health Net California)

CPT and ICD-10-CM codes referenced in Health Net California's clinical policy 'HNCA.CP.MP.496 - Gender Affirming Procedures'. Intended for segmentation of gender-affirming care under AB352.

Health Net Bulletin 24-351

Health Net's bulletin 24-351 explicitly tells providers that services defined in policies like HNCA.CP.MP.496 must be:

  • Blocked from automatic sharing with the California Data Exchange Framework (DxF).
  • Omitted from responses to out-of-state subpoenas or investigations.
  • Flagged within the EHR to prevent unauthorized access by users outside of California.

Where to Find and Download HNCA.CP.MP.496.pdf Health Net maintains this policy in several locations within their provider libraries:

  • Direct PDF Link: HNCA.CP.MP.496 - Gender Affirming Procedures
  • The Provider Library Archive: You can find this by navigating to Health Net Provider Library > Resources > Clinical Policies and searching for Gender Affirming Procedures or the code 496.

Terminology: Code Systems

These define new code systems used by systems conforming to this implementation guide.

Health Information Sensitivity Categories

Code system defining sensitivity categories for health information segmentation under California AB352.

Note did not use HL7 v2-ActCodes as two of the three categories are not represented there, and the GENDER code may be more broad than GENDER_AFFIRMING_CARE as intended here.

Example: Example Instances

These are example instances that show what data produced and consumed by systems conforming with this implementation guide might look like.

AB352 Organizational Privacy Consent - Allow All

A FHIR Consent instance that is an explicit consent for AB 352 protected data, with provisions that reflect Patient allowing all access.

  • permit TPO
AB352 Organizational Privacy Consent - breath

A FHIR Consent instance that is an explicit consent for AB 352 protected data, with provisions that reflect the statutory requirements, with auto-filter bypassed for in-state recipients.

Breath first - not possible with R6 consent structure, but shown here for clarity.

  • permit TPO
    • deny sensitive data [for TPO]
    • permit in-state sensitive data [for TPO]
AB352 Organizational Privacy Consent - depth

A FHIR Consent instance that is an explicit consent for AB 352 protected data, with provisions that reflect the statutory requirements, with auto-filter bypassed for in-state recipients.

  • permit TPO
    • deny sensitive data [for TPO]
      • permit in-state [sensitive data for TPO]
California Location

Location resource representing California for use in Consent provisions.

DocumentReference of the XACML Consent policy

Example of a xml XACML Consent policy for Patient 12345 in a DocumentReference.

DocumentReference of the XACML overriding policy

Example of a xml XACML overriding policy DocumentReference.

Dummy Patient example

Dummy patient example for completeness sake. No actual use of this resource other than an example target

Example FHIR Consent with copy of XACML Policies

An example instance of a FHIR Consent resource that references XACML policies for access, and a copy of the patient specific XACML policy is included as a DocumentReference.

Example FHIR Consent with references to XACML Policies

An example instance of a FHIR Consent resource that references XACML policies for access, and does not include any rules directly in the Consent.