December 3, 2020 – Advisory: Consent May Be Overridden at the System-Level for Clinical Information Type Consent Regardless of the “Allow Override Consent” Setting

InterSystems has identified a defect affecting the ability to block the overriding of Clinical Information Type consent at the system level.

This problem exists for:

  • HealthShare Information Exchange 2018.1.x
  • HealthShare Unified Care Record 2019.1.x, 2019.2.x, 2020.1.x, and 2020.2.x

Consent in HealthShare may be applied in two contexts, MPI and Clinical Information Type (CIT), and at three levels, patient-, facility-, and system-level. It is possible to configure HealthShare to permit emergency access by allowing a user to override consent to access a patient record or clinical information. This override is also known as “break the glass”. If overriding consent is permitted, users will see options to enable this in the Patient Search screen.

When configuring MPI consent at the system-level, there is a checkbox to “Allow Override Consent Policy”. By default, this checkbox is unchecked, meaning that users will not be able to override consent in any situation. If the checkbox is checked, users will be permitted to override consent. The same “Allow Override Consent Policy” checkbox exists when configuring CIT consent at the system-level. However, this checkbox has no effect regardless of whether it is checked or unchecked. The system will apply the same setting from the MPI system-level consent. Therefore, it is possible to have “Allow Override Consent Policy” permitted at the MPI level and appear to not be permitted at the CIT level; however, if a user overrides consent in the Patient Search screen that override will apply to both MPI and CIT consent.

As a result of this issue, there is no way to block the overriding of CIT consent at the system level. It may be blocked at the patient level by checking “Prevent Override Consent Policy”.

A fix is not yet available for this issue. While the fix is under development, InterSystems recommends the following actions:

Step 1: Review your system-level MPI and CIT consent policies:

 “Allow Override Consent Policy” Setting 
ScenarioMPI Consent
(System Level)
CIT Consent
(System Level)
Outcome
1CheckedChecked or UncheckedOverriding consent will apply to both types of consent
2UncheckedUncheckedOverriding consent will not be permitted
3UncheckedCheckedOverriding consent will not be permitted as MPI override must be permitted for CIT override to function.

Step 2: In Scenario 1, if customers need to block overriding CIT consent, use the “Prevent Override Consent Policy” setting at the patient-level of CIT consent.

The correction for this defect is identified as HSIEC-3893 and once completed an update to this Advisory will be posted.

If you have any questions regarding this advisory, please contact the Worldwide Response Center (WRC).