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Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

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Page 1: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Electronic Submission of Medical Documentation (esMD)

Identity Proofing Sub-Workgroup

October 3, 2012

Page 2: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Sub Workgroup: Identity Proofing

Goal– Define required process for identity proofing of

healthcare individuals and organizations for esMD

Requirements– NIST SP 800-63-1 Level 3 authentication

(December 2011)– Federal Bridge Certification Authority Medium Level

In-Scope – RA qualifications and certification– Combining RA process with other healthcare identity

proofing (e.g. credentialing)– Policy issues regarding identity proofing

Out-of-Scope– Digital Credential Management– Digital Signatures– Delegation of Rights

Deliverable: “Summary White Paper”– Assumptions– Statement of Problem– Recommended Solution(s)

• Review of Standards (e.g. NIST, FICAM, FBCA)

• Certification requirements for RAs• Proof of identity requirements for

– Entities– Individuals

• Allowed proofing processes (e.g. as part of credentialing?)

• Frequency of Identity review• Appeals process for denial• Variation based on specific

credentials/use?• Revocation (triggers and process)

– Identify gaps in current policy impacting Identity Proofing

– References

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Page 3: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Schedule for Identity Proofing SWG

Date Topic Deliverable(s)

September 26, 2012 Standards (NIST/FBCA)

List and review of standards

October 3, 2012 Industry examples List and review industry examples

October 10, 2012 Requirements for identity

Requirements for individuals and organizations

October 17, 2012 RA requirements “Certification” process for RAs

October 24, 2012 RA processes Combine with, frequency, appeals, revocation

October 31, 2012 Gaps in policy and standards

Identify gaps in standards, process and policy and make recommendations

November 7, 2012 Review SWG recommendation

Review final report

Page 4: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Definitions

Identity (NIST)

A set of attributes that uniquely describe a person within a given context.

Identity (Proposed)

A set of attributes that uniquely describe a person or legal entity within a given context.

Identity Proofing (NIST)

The process by which a Credential Service Provider (CSP) and a Registration Authority (RA) collect and verify information about a person for the purpose of issuing credentials to that person.

Identity Proofing (Proposed)

The process by which a Credential Service Provider (CSP) and a Registration Authority (RA) collect and verify information about a person or legal entity for the purpose of issuing credentials to that person or legal entity.

4

Page 5: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

General Requirements Solution must

be implementable for pilot in Q1/Q2 2013 scale to all providers and payers minimize the operational impact required to establish , maintain

or use a digital identity provide for non-repudiation without resorting to audit logs or

validation of system configuration Standards -- required

NIST 800-63-1 Level 3/$ (December 2011) NIST 800-57 Part 1 (Revision 3 July 2012) Federal Bridge Certification Authority Medium Level X.509v3+ Digital Certificates

Page 6: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Standards for Identity ProofingDocument Link Title & Version / Notes Date

NIST SP 800-63-1 Electronic Authentication Guideline Dec 2011FBCA X.509 Certificate Policy X.509 Certificate Policy for the Federal Bridge Certification Authority,

Version 2.25Dec 9 2011

FICAM Roadmap and Implementation Guidance

Federal Identity, Credential, and Access Management Roadmap and Implementation Guidance, Version 2.0

Dec 2 2011

IETF RFC 3647and FPKIPA

Internet X.509 Public Key Infrastructure Certificate Policy and Certification Practices FrameworkandX.509 Certificate Policy for the U.S. Federal PKI Common Policy Framework, Version 3647 – 1.17

Nov 2003and Dec 9 2011

FIPS PUB 201-1 Personal Identity Verification of Federal Employees and Contractors Mar 2006

IETF RFC 5280 Internet X.509 Public Key Infrastructure Certificate and Certificate Revocation List Profile

May 2008

IETF RFC 6711 An IANA Registry for Level of Assurance (LoA) Profiles Aug 2012

ISO Standards Catalogue webpage ISO standards publications are proprietary. Subcommittee/WG structure can be found here.

Page 7: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

NIST 800-63-1 Separation of RA and CSP functions

• A common reason for breaking up the registration process as described above is to allow the subscriber to register or obtain tokens for use in two or more environments. This is permissible as long as the tokens individually meet the appropriate assurance level. However, if the exact number of tokens to be issued is not agreed upon early in the registration process, then the tokens should be distinguishable so that Verifiers will be able to detect whether any suspicious activity occurs during the first few uses of a newly issued token.

• If a valid credential has already been issued, the CSP may issue another credential of equivalent or lower assurance. In this case, proof of possession and control of the original token may be substituted for repeating the identity proofing steps. (This is a special case of a derived credential. See Section 5.3.5 for procedures when the derived credential is issued by a different CSP.) Any requirements for credential delivery at the appropriate Level shall still be satisfied.

Page 8: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

NIST 800-63-1 Level 2 Identity Proofing Requirements

In Person Remote

Basis for issuing credentials

Possession of a valid current primary government picture ID that contains Applicant’s picture, and either address of record or nationality of record (e.g., driver’s license or Passport)

Possession of a valid current government ID (e.g., driver’s license or Passport) number and financial or utility account number (e.g. checking account savings account, utility account, loan or credit cared, or tax ID) confirmed via records of either the government ID or account number. Note that confirmation for the financial or utility account may require supplemental information rom the applicant.

RA and CSP actions

RA inspects photo-ID,; compares picture to Applicant and records the ID number, address and date of birth (DoB). (RA optionally reviews personal information in records to support issuance process “a” below)

If the photo-ID appears valid and the photo matches Applicant then:a) If personal information in records includes a

telephone number or e-mail address, the CSP issues credentials in a manner that confirms the ability for the Applicant to receive telephone communication or text messages a t phone number or e-mail address associated with the applicant in records. Any secret sent over an unprotected session shall be reset upon first use: or

b) If ID confirms address so f record, RA authorizes or CSP issues credentials. Notices is sent to address of record, or;

c) If ID does not confirm address of record, CSP issues credentials in manner that confirms the claimed address.

RA inspects both ID number and account number supplied by Applicant (e.g., for correct number of digits). Verifies information provided by Applicant including ID number OR account number through record checks either with the applicable agency or institution or through credit bureaus or similar databases, and confirms that: name, DoB, address and other personal information in records are on balance consistent with the application and sufficient to identify a unique individual. For utility account numbers, confirmation shall be performed by verifying knowledge of recent account activity. (This technique may also be applied to some financial accounts.)

Address/phone number confirmation and notification:a) CSP issues credentials in a manner that confirms the ability of the applicant to

receive mail at a physical address associated with the Applicant in records; or b) If personal information in records includes a telephone number or e-mail

address, the CSP issues credentials in a manner that confirms the ability of the Applicant to receive telephone communications or text message at phone number or e-mail address associated with the Applicant in records. Any secret sent over an unprotected session shall be reset upon first use; or

c) CSP issues credentials. RA or CSP sends notice to an address of record.

Page 9: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

NIST 800-63-1 Level 3 Identity Proofing Requirements

In Person Remote

Basis for issuing credentials

Possession of a verified current primary government picture ID that contains Applicant’s picture, and either address of record or nationality of record (e.g., driver’s license or Passport)

Possession of a valid Government ID (e.g., a driver’s license or Passport) number and a financial or utility account number (e.g., checking account, savings account, utility account, loan or credit card) confirmed via records of both numbers. Note that confirmation of the financial or utility account may require supplemental information from the applicant.

RA and CSP actions

RA inspects photo-ID and verifies via the issuing government agency or through credit bureaus or similar databases. Confirms that: name, DoB, address and other personal information in record are consistent with the application. Compares picture to Applicant and records ID number.

If ID is valid and photo matches Applicant, then: a) If personal information in records includes a telephone

number, the CSP issues credentials in a manner that confirms the ability of the Applicant to receive telephone communications at a number associated with the Applicant in records, while recording the Applicant’s voice or using alternative means that establish an equivalent level of non-repudiation; or

b) If ID confirms address of record, RA authorizes or CSP issues credentials. Notice is sent to address of record, or;

c) If ID does not confirm address of record, CSP issues credentials in a manner that confirms the claimed address.

RA verifies information provided by Applicant including ID number AND account number through record checks either with the applicable agency or institution or through credit bureaus or similar databases, and confirms that: name, DoB, address and other personal information in records are consistent with the application and sufficient to identify a unique individual. For utility account numbers, confirmation shall be performed by verifying knowledge of recent account activity. (This technique may also be applied to some financial accounts.)

Address confirmation:

a) CSP issues credentials in a manner that confirms the ability of the applicant to receive mail at a physical address associated with the Applicant in records; or

b) If personal information in records includes a telephone number, the CSP issues credentials in a manner that confirms the ability of the Applicant to receive telephone communications at a number associated with the Applicant in records. CSP records the Applicant’s voice or using alternative means that establish an equivalent level of non-repudiation.

Page 10: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

NIST 800-63-1 Level 4 Identity Proofing Requirements

In Person Remote

Basis for issuing credentials

In-person appearance and verification of: a) a current primary Government Picture ID that contains Applicant’s picture, and either address of

record or nationality of record (e.g., driver’s license or passport), and; b) either a second, independent Government ID document that contains current corroborating

information (e.g., either address of record or nationality of record), OR verification of a financial account number (e.g., checking account, savings account, loan or credit card) confirmed via records.

Not Applicable

RA and CSP actions

Primary Photo ID: RA inspects photo-ID and verifies via the issuing government agency or through credit bureaus or similar databases. Confirms that: name, DoB, address, and other personal information in record are consistent with the application. Compares picture to Applicant and records ID number.Secondary Government ID or financial accounta) RA inspects secondary Government ID and if apparently valid, confirms that the identifying information

is consistent with the primary Photo-ID, or;b) RA verifies financial account number supplied by Applicant through record checks or through credit

bureaus or similar databases, and confirms that: name, DoB, address, and other personal information in records are on balance consistent with the application and sufficient to identify a unique individual.

[Note: Address of record shall be confirmed through validation of either the primary or secondary ID.]

Current Biometric RA records a current biometric (e.g., photograph or fingerprints) to ensure that Applicant cannot repudiate application.

Credential Issuance CSP issues credentials in a manner that confirms address of record.

Not Applicable

Page 11: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

FBCA Identification Requirements by Assurance Level

Level Identification Requirements

Basisc Identity may be established by in-person proofing before a Registration Authority or Trusted Agent; or remotely verifying information provided by applicant including ID number and account number through record checks either with the applicable agency or institution or through credit bureaus or similar databases, and confirms that: name, DoB, address and other personal information in records are consistent with the application and sufficient to identify a unique individual. Address confirmation: a) Issue credentials in a manner that confirms the address of record supplied by the applicant; or b) Issue credentials in a manner that confirms the ability of the applicant to receive telephone communications at a number associated with the applicant in records, while recording the applicant’s voice.

Medium (all policies)

Identity shall be established by in-person proofing before the Registration Authority, Trusted Agent or an entity certified by a State or Federal Entity as being authorized to confirm identities; information provided shall be verified to ensure legitimacy. A trust relationship between the Trusted Agent and the applicant which is based on an in-person antecedent may suffice as meeting the in-person identity proofing requirement. Credentials required are one Federal Government-issued Picture I.D., one REAL ID Act compliant picture ID1, or two Non-Federal Government I.D.s, one of which shall be a photo I.D. (e.g., Non-REAL ID Act compliant Drivers License). Any credentials presented must be unexpired.

Clarification on the trust relationship between the Trusted Agent and the applicant, which is based on an in-person antecedent identity proofing event, can be found in the “FBCA Supplementary Antecedent, In-Person Definition” document.

For PIV-I, credentials required are two identity source documents in original form. The identity source documents must come from the list of acceptable documents included in Form I-9, OMB No. 1115-0136, Employment Eligibility Verification. At least one document shall be a valid State or Federal Government-issued picture identification (ID). For PIV-I, the use of an in-person antecedent is not applicable.

High Identity established by in-person appearance before the Registration Authority or Trusted Agent; information provided shall be checked to ensure legitimacy Credentials required are either one Federal Government-issued Picture I.D., or two Non-Federal Government I.D.s, one of which shall be a photo I.D. (e.g., Drivers License)

Page 12: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

PIVFor compliance with the PIV-I control objectives, departments and agencies shall follow an identity proofing and registration

process that meets the requirements defined below when issuing identity credentials.

5 PERSONAL IDENTITY VERIFICATION (PIV) OF FEDERAL EMPLOYEES AND CONTRACTORS

+ The organization shall adopt and use an approved identity proofing and registration process.

+ The process shall begin with initiation of a National Agency Check with Written Inquiries (NACI) or other Office of Personnel Management (OPM) or National Security community investigation required for Federal employment. This requirement may also be satisfied by locating and referencing a completed and successfully adjudicated NACI. At a minimum, the FBI National Criminal History Check (fingerprint check) shall be completed before credential issuance. Beginning with Part 2, Identity credentials issued to individuals without a completed NACI or equivalent must be electronically distinguishable from identity credentials issued to individuals who have a completed investigation. Appendix C, Background Check Descriptions, provides further details on NAC and NACI.

+ The applicant must appear in-person at least once before the issuance of a PIV credential.

+ During identity proofing, the applicant shall be required to provide two forms of identity source documents in original form. The identity source documents must come from the list of acceptable documents included in Form I-9, OMB No. 1115-0136, Employment Eligibility Verification. At least one document shall be a valid State or Federal government-issued picture identification (ID).

+ The PIV identity proofing, registration and issuance process shall adhere to the principle of separation of duties to ensure that no single individual has the capability to issue a PIV credential without the cooperation of another authorized person.

The identity proofing and registration process used when verifying the identity of the applicant shall be accredited by the department or agency as satisfying the requirements above and approved in writing by the head of the Federal department or agency. Two examples of processes that meet these requirements are provided in Appendix A, PIV Processes.

Page 13: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

DEA Example

• Physicians have the option of e-prescribing controlled substances as of June 1, 2010, if they comply with specific requirements, as described below.

• Physicians must first undergo a verification process (either in person or remotely) in order to receive authorization to e-prescribe controlled substances.

• Access controls must be established prior to e-prescribing controlled substances.

• Physicians must use a two-factor credential to e-prescribe controlled substances.

• Physicians must comply with notification requirements if they lose their hard token or if they discover that their security controls have been compromised.

• Physicians must use a compliant e-prescribing application in order to e-prescribe controlled substances.

Source: http://www.ama-assn.org/ama1/pub/upload/mm/399/dea-eprescriptions-final-rule-summary.pdf

Page 14: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

DEA Example• Identity Proofing

• Authentication must occur by an authorized third party (federally approved credential service provide (CSP) or CAs)

• CSPs and CAs are required to conduct identity proofing at NIST SP 800-63-1 Assurance Level 3 (requiring either in-person or remote identity proofing)

• Logical access controls are set after authentication credentials are issued, which verifies that the authenticated user has the authority to perform the requested operation (may be role-based).

• Someone other than the prescriber needs to authenticate the prescriber

• Credentialing can also be completed in-house within a hospital credential office, but two people must be responsible for this

• Verification of identity is required via two-factor authentication• If a hard token is used, it must be a cryptographic device or meet the Federal Information

Processing Standard 140-2 Security Level 1

• Physicians can use their own digital certificate to sign eRxs for controlled substances, and can be used as part of the two-factor authentication as long as the certificate is from a CA cross-certified with the FBCA at the basic assurance level (this is being confirmed)

Page 15: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Sec. 1311.20 Coordinators for CSOS digital certificate holders.

(a) Each registrant, regardless of number of digital certificates issued, must designate one or more responsible persons to serve as that registrant's CSOS coordinator regarding issues pertaining to issuance of, revocation of, and changes to digital certificates issued under that registrant's DEA registration. While the coordinator will be the main point of contact between one or more DEA registered locations and the CSOS Certification Authority, all digital certificate activities are the responsibility of the registrant with whom the digital certificate is associated. Even when an individual registrant,i.e. , an individual practitioner, is applying for a digital certificate to order controlled substances a CSOS Coordinator must be designated; though in such a case, the individual practitioner may also serve as the coordinator.(b) Once designated, coordinators must identify themselves, on a one-time basis, to the Certification Authority. If a designated coordinator changes, the Certification Authority must be notified of the change and the new responsibilities assumed by each of the registrant's coordinators, if applicable. Coordinators must complete the application that the DEA Certification Authority provides and submit the following:(1) Two copies of identification, one of which must be a government-issued photographic identification.(2) A copy of each current DEA Certificate of Registration (DEA form 223) for each registered location for which the coordinator will be responsible or, if the applicant (or their employer) has not been issued a DEA registration, a copy of each application for registration of the applicant or the applicant's employer.(3) The applicant must have the completed application notarized and forward the completed application and accompanying documentation to the DEA Certification Authority.(c) Coordinators will communicate with the Certification Authority regarding digital certificate applications, renewals and revocations. For applicants applying for a digital certificate from the DEA Certification Authority, and for applicants applying for a power of attorney digital certificate for a DEA registrant, the registrant's Coordinator must verify the applicant's identity, review the application package, and submit the completed package to the Certification Authority.

Page 16: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

DEA Example

• Under the IFR, e-prescribers must prove their identities using two of the three following factors:• Something you know, such as a password or response to a

challenge question; • Something you have, such as a hard token or device separate

from the computer; or • Something you are, such as biometric data.

Page 17: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

DIRECT

• Key Concepts of the DIRECT project (from presentation by John Hall)

• Direct enables push-based transport – a sender pushes information to one or more recipients

• Direct Messages act as containers of health information

• Direct Addresses are used to route Direct Messages

• Digital certificates are used to protect Direct Messages in transit and to express trust relationships

• SMTP is used to transport Direct Messages

• Security/Trust Agents (STAs) such as Health Information Service Providers (HISPs) are responsible for providing the services necessary for exchange using Direct

Page 18: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

DIRECT

• Each Direct Address must have at least one X.509v3 digital certificate associated with it

– Address-bound certificate – certificate tied to a specific Direct Address– Domain-bound certificate – certificate tied to the Domain that is part of a Direct

Address (also known as organizationally-bound certificate)

• Digital certificates are used within Direct to secure Direct Messages in transit and to express trust relationships

• Certificates in Direct are not intended to be used to protect data at rest or to provide legal non-repudiation through signing of content.

• Certificates in Direct are used for both encryption and signing– Encryption protects data from access by attackers and restricts access to data

to receiving STA– Signing provides integrity protection and “good enough” non-repudiation for

transport (signature ties sending STA to transaction)

Page 19: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

DIRECT

• Trust relationships are expressed using digital certificates. A party may choose to trust a specific certificate, as well as any certificate that cryptographically chains to a trust anchor.

• Certificates are issued only to parties that agree to abide by specified trust policies. These policies often cover:

– Certificate applicability (i.e., purposes for which certificates are issued)– Identity verification of parties– Security requirements of parties

• Setting trust policy is outside the domain of the Direct Project.– For health information exchange, policy originates with the HITPC and ONC– Communities may further build upon those policies

Page 20: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

DIRECT

Direct Project does not require particular policies or processes for identity proofing– Matter of policy that is outside scope of Direct Project

All states, implementing communities, and national HISPs do require entities seeking to enroll to provide identifying information. Information required is based on:– What is needed to obtain a certificate– What is needed to establish a foundation of trust between exchange

participants

20

Individual• In-person proofing before a Registration Authority,

trusted agent, or an entity such as a notary public• Requires one of: Federal Government-issued photo

ID, READ ID Act compliant photo ID, or two non-federal IDs (one of which must be a photo ID

Organization• Requires organization name, postal address,

documentation proving existence of the organization• Organization must be HIPAA covered or a BA, or a

healthcare-related organization that protects PHI with HIPAA-equivalent protections

• Also requires identity validation of the requesting organizational representative

• Organizations further identity proof their agents

Page 21: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Electronic Submission of Medical Documentation (esMD)

Digital Signature and Delegation of Rights

Sub-Workgroup

October 3, 2012

Page 22: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Schedule for Identity Proofing SWGDate Topic Deliverable(s)

September 26, 2012 Standards List and review of standards

October 3, 2012 Standards and industry examples

List and review of additional standards industry examples

October 10, 2012 Transaction and AoR digital signature and delegation process

Document digital signature and delegation of rights process

October 17, 2012 Transaction and AoR signature and delegation artifacts

Document digital signature and delegation of rights artifacts

October 24, 2012 Validation process for non-repudiation review

Document validation process with assurance of non-repudiation of signer and delegation(s)

October 31, 2012 Gaps in policy and standards

Identify gaps in standards, process and policy and make recommendations

November 7, 2012 Review SWG recommendation

Review final report

Page 23: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

DefinitionsDigital Signature (NIST)

The result of a cryptographic transformation of data that, when properly implemented, provides a mechanism for verifying origin authentication, data integrity and signatory non-repudiation.

Data Integrity (NIST)

Data integrity is a property whereby data has not been altered in an unauthorized manner since it was created, transmitted or stored. Alteration includes the insertion, deletion and substitution of data.

Non-repudiation (NIST)

Non-repudiation is a service that is used to provide assurance of the integrity and origin of data in such a way that the integrity and origin can be verified by a third party. This service prevents an entity from successfully denying involvement in a previous action.

Delegation of Rights

The ability to delegate rights or authority to another to act in a specific capacity on behalf of the grantor of the right. Must include the digital identity of the grantor, the digital identity of the grantee, the rights granted, duration of grant in a format that is usable in transaction and AoR signature events and is verifiable by a third party for non-repudiation purposes.

Page 24: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

General Requirements Solution must

be implementable for pilot in Q1/Q2 2013 scale to all providers and payers minimize the operational impact required to establish , maintain

or use a digital identity provide for non-repudiation without resorting to audit logs or

validation of system configuration Standards -- required

NIST 800-63-1 Level 3/4 (December 2011) NIST 800-57 Part 1 (Revision 3 July 2012) Federal Bridge Certification Authority Medium Level X.509v3+ Digital Certificates

Page 25: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Sub Workgroup: Digital Signatures

Goal– Define process, artifacts and standards for

transaction and document bundle digital signatures for esMD

Requirements– Must provide for non-repudiation as part of the

credentials and artifacts– Must ensure data integrity

In-Scope– Use Case 1 and 2 transactions– AoR L1 (Signature binding to aggregated

document bundle)– Signature workflow– Signature artifacts– Identification of relevant standards

Out-of-Scope– AoR L2– AoR L3

Deliverable: “Summary White Paper”– Assumptions– Statement of Problem– Recommended Solution(s)

• Review of Standards (e.g. OASIS, IHE, HL7, …)

• Transaction signature process• Transaction artifacts to meet Use Case

1 and 2 requirements• Document Bundle signature process• Artifacts to meet AoR L1 requirements• Data Integrity requirements• Non-repudiation assurance

– Identify gaps in current policy impacting Digital Signatures

– References

25

Page 26: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Sub Workgroup: Delegation and Proxy

Goal– Define credentials, artifacts and process for

Delegation of Rights for esMD

Requirements– Must provide for non-repudiation (NIST definition)

as part of the credentials and artifacts– Revocable

In-Scope– Use Case 1 and AoR L1 Delegation of Rights

requirements– Delegation/Proxy workflow– Delegation/Proxy artifacts– Identification of relevant standards

Out-of-Scope– AoR L2– AoR L3

Deliverable: “Summary White Paper”– Assumptions– Statement of Problem– Recommended Solution(s)

• Review of Standards (e.g. OASIS, IHE, HL7, …)

• Proxy/Delegation Credential/Artifact(s) • Operational consideration for

Proxy/Delegation Creation• Scope/Content of Proxy/Delegation• Revocation of Proxy• Credential Transaction proxy

requirements• Transaction artifacts to meet Use Case

1 requirements• Document Bundle proxy signature

process• Artifacts to meet AoR L1 signature

proxy requirements• Data Integrity requirements• Non-repudiation assurance

– Identify gaps in current policy impacting Delegation & Proxy

– References

26

Page 27: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Standards for Digital Signature and Delegation of Rights

Document Link Title & Version / Notes DateITI TF-1 IHE IT Infrastructure Technical Framework: Volume 1: Integration Profiles, Revision 9.0 Aug 31, 2012

ITI TF-2a IHE IT Infrastructure Technical Framework: Volume 2a: Transactions Part A – Sections 3.1-3.28, Revision 9.0 Aug 31 2012

ITI TF-2b IHE IT Infrastructure Technical Framework: Volume 2b: Transactions Part B – Sections 3.29-3.51, Revision 9.0 Aug 31 2012

ITI TF-3 IHE IT Infrastructure Technical Framework: Volume 3: Cross-Transaction Specifications and Content Specifications, Revision 9.0

Aug 31 2012

NIST SP 800-63-1 Electronic Authentication Guideline Dec 2011OASIS DSS Core Spec Digital Signature Service Core Protocols, Elements, and Bindings, Version 1.0

All DSS Standards

Apr 11 2007

XML DigSig XML Signature Syntax and Processing (Second Edition), W3C Recommendation W3C Jun 10 2008

FIPS PUB 186-3 Digital Signature Standard Jun 2009IETF RFC 6277 Online Certificate Status Protocol Algorithm Agility Jun 2011

IETF RFC 6283 Extensible Markup Language Evidence Record Syntax Jul 2011

IETF RFC 5698 Data Structure for the Security Suitability of Cryptographic Algorithms Nov 2009

IETF RFC 5280 Internet X.509 Public Key Infrastructure Certificate and Certificate Revocation List Profile May 2008IETF RFC 5276 Using the Server-Based Certificate Validation Protocol to Convey Long-Term Evidence Records Aug 2008IETF RFC 4998 Evidence Record Syntax Aug 2007IETF RFC 3851 Secure/Multipurpose Internet Mail Extensions (S/MIME) Version 3.1

Message SpecificationJuly 2004

IETF RFC 3820 Internet X.509 Public Key Infrastructure Proxy Certificate Profile Jun 2004

FBCA X.509 Certificate Policy X.509 Certificate Policy for the Federal Bridge Certification Authority, Version 2.25 Dec 9 2011

Page 28: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

Assumptions

AoR Level 1• Source record for episode of care exists and has been finalized• Need to address externally provided records (e.g. from another

provider) that are the basis for a decision• Need to address transition to digital signature (probably applies to

AoR Level 2 and 3

Page 29: Electronic Submission of Medical Documentation (esMD) Identity Proofing Sub-Workgroup October 3, 2012

W3C XMLdigsig

Integrity "The property that data has not been changed, destroyed, or lost in an unauthorized or accidental manner." [SEC] A simple checksum can provide integrity from incidental changes in the data; message authentication is similar but also protects against an active attack to alter the data whereby a change in the checksum is introduced so as to match the change in the data.  Object

Authentication, Message The property, given an authentication code/protected checksum, that tampering with both the data and checksum, so as to introduce changes while seemingly preserving integrity, are still detected. "A signature should identify what is signed, making it impracticable to falsify or alter either the signed matter or the signature without detection." [Digital Signature Guidelines, ABA].

Authentication, Signer The property that the identity of the signer is as claimed. "A signature should indicate who signed a document, message or record, and should be difficult for another person to produce without authorization." [Digital Signature Guidelines, ABA] Note, signer authentication is an application decision (e.g., does the signing key actually correspond to a specific identity) that is supported by, but out of scope, of this specification.

This document specifies XML digital signature processing rules and syntax. XML Signatures provide integrity, message authentication, and/or signer authentication services for data of any type, whether located within the XML that includes the signature or elsewhere.

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FIPS – 186 (Digital Signature Standards)

INTRODUCTION .................................................................................................................................. 1

2. GLOSSARY OF TERMS, ACRONYMS AND MATHEMATICAL SYMBOLS ....................................... 2

2.1 TERMS AND DEFINITIONS ................................................................................................................ 2

2.2 ACRONYMS ................................................................................................................................... 5

2.3 MATHEMATICAL SYMBOLS................................................................................................................6

3. GENERAL DISCUSSION....................................................................................................................... 9

3.1 INITIAL SETUP ............................................................................................................................... 11

3.2 DIGITAL SIGNATURE GENERATION.................................................................................................. 12

3.3 DIGITAL SIGNATURE VERIFICATION AND VALIDATION ....................................................................... 13

THE DIGITAL SIGNATURE ALGORITHM (DSA) ............................................................................... 15

4.1 DSA PARAMETERS........................................................................................................................ 15

4.2 SELECTION OF PARAMETER SIZES AND HASH FUNCTIONS FOR DSA ................................................ 15

4.3 DSA DOMAIN PARAMETERS........................................................................................................... 16

4.3.1 Domain Parameter Generation......................................................................................17

4.3.2 Domain Parameter Management...................................................................................17

4.4 KEY PAIRS .................................................................................................................................. 17

4.4.1 DSA Key Pair Generation..............................................................................................17

4.4.2 Key Pair Management ...................................................................................................18

4.5 DSA PER-MESSAGE SECRET NUMBER........................................................................................... 18

4.6 DSA SIGNATURE GENERATION ...................................................................................................... 19

4.7 DSA SIGNATURE VERIFICATION AND VALIDATION............................................................................ 19

5. THE RSA DIGITAL SIGNATURE ALGORITHM.................................................................................. 22

5.1 RSA KEY PAIR GENERATION ......................................................................................................... 22

5.2 KEY PAIR MANAGEMENT ................................................................................................................ 23

5.3 ASSURANCES...............................................................................................................................23

5.4 ANS X9.31 ................................................................................................................................ 23

5.5 PKCS #1 ................................................................................................................................... 24

6. THE ELLIPTIC CURVE DIGITAL SIGNATURE ALGORITHM (ECDSA).............................................26

6.1 ECDSA DOMAIN PARAMETERS...................................................................................................... 26

6.1.1 Domain Parameter Generation......................................................................................26

6.1.2 Domain Parameter Management...................................................................................28

6.2 PRIVATE/PUBLIC KEYS .................................................................................................................. 28

6.2.1 Key Pair Generation.......................................................................................................28

6.2.2 Key Pair Management ...................................................................................................29

6.3 SECRET NUMBER GENERATION...................................................................................................... 29

6.4 ECDSA DIGITAL SIGNATURE GENERATION AND VERIFICATION ........................................................ 29

6.5 ASSURANCES...............................................................................................................................30

APPENDIX A: GENERATION AND VALIDATION OF FFC DOMAIN PARAMETERS ........................... 31

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Review of W3C XMLdigsig

• XML Signatures are applied to arbitrary digital content (data objects) via an indirection. • Data objects are digested, the resulting value is placed in an element (with other

information) and that element is then digested and cryptographically signed. • XML digital signatures are represented by the Signature element which has the following

structure (where "?" denotes zero or one occurrence; "+" denotes one or more occurrences; and "*" denotes zero or more occurrences):

<Signature ID?>

<SignedInfo>

<CanonicalizationMethod/>

<SignatureMethod/>

(<Reference URI? >

(<Transforms>)?

<DigestMethod>

<DigestValue>

</Reference>)+

</SignedInfo>

<SignatureValue>

(<KeyInfo>)?

( <Object ID?>)*

</Signature>

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Review of W3C XML DigSig• Signatures are related to data objects via Uniform Resource

Identifiers (URIs)• Within an XML document, signatures are related to local data

objects via fragment identifiers• Local data can either be within an enveloping signature (parent) or

be an enclosed enveloped signature (child)

• Detached signatures can be utilized over external network resources or local data objects residing within the same XML document as sibling elements• Care should be taken to avoid collisions violating the ID

uniqueness validity constraint by choosing different names for the signature element and other elements such as the ID

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W3C XML DigSig

Required element consists of two processes: Validation of Signature and Validation of Each Reference

Indicates the key to be used to validate the signature

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W3C XML DigSig[s02-12] The required SignedInfo element is the information that is actually signed. Core validation of SignedInfo

consists of two mandatory processes: validation of the signature over SignedInfo and validation of each Reference digest within SignedInfo. Note that the algorithms used in calculating the SignatureValue are also included in the signed information while the SignatureValue element is outside SignedInfo.

[s03] The CanonicalizationMethod is the algorithm that is used to canonicalize the SignedInfo element before it is digested as part of the signature operation. Note that this example, and all examples in this specification, are not in canonical form.

[s04] The SignatureMethod is the algorithm that is used to convert the canonicalized SignedInfo into the SignatureValue. It is a combination of a digest algorithm and a key dependent algorithm and possibly other algorithms such as padding, for example RSA-SHA1. The algorithm names are signed to resist attacks based on substituting a weaker algorithm. To promote application interoperability we specify a set of signature algorithms that MUST be implemented, though their use is at the discretion of the signature creator. We specify additional algorithms as RECOMMENDED or OPTIONAL for implementation; the design also permits arbitrary user specified algorithms.

[s05-11] Each Reference element includes the digest method and resulting digest value calculated over the identified data object. It also may include transformations that produced the input to the digest operation. A data object is signed by computing its digest value and a signature over that value. The signature is later checked via reference and signature validation.

[s14-16] KeyInfo indicates the key to be used to validate the signature. Possible forms for identification include certificates, key names, and key agreement algorithms and information -- we define only a few. KeyInfo is optional for two reasons. First, the signer may not wish to reveal key information to all document processing parties. Second, the information may be known within the application's context and need not be represented explicitly. Since KeyInfo is outside of SignedInfo, if the signer wishes to bind the keying information to the signature, a Reference can easily identify and include the KeyInfo as part of the signature.

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Review of Proxy Certificate Standards• IETF 3280

• Proxy Certificate: A certificate that is derived from, and signed by, a normal X.509 Public Key End Entity Certificate or by another Proxy Certificate to provide restricted proxying and delegation within a PKI based authentication system

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Proxy Certificate (PC) Standards

• A Proxy Certificate is an X.509 public key certificate with the following properties: • It is signed by either an X.509 End Entity Certificate (EEC), or by another PC. This

EEC or PC is referred to as the Proxy Issuer (PI). • It can sign only another PC. It cannot sign an EEC. • It has its own public and private key pair, distinct from any other EEC or PC. • It has an identity derived from the identity of the EEC that signed the PC. When a

PC is used for authentication, in may inherit rights of the EEC that signed the PC, subject to the restrictions that are placed on that PC by the EEC.

• Although its identity is derived from the EEC's identity, it is also unique. This allows this identity to be used for authorization as an independent identity from the identity of the issuing EEC, for example in conjunction with attribute assertions as defined in [i3].

• It contains a new X.509 extension to identify it as a PC and to place policies on the use of the PC. This new extension, along with other X.509 fields and extensions, are used to enable proper path validation and use of the PC.

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Proxy Certificate

• The process of creating a PC is as follows: • A new public and private key pair is generated.• That key pair is used to create a request for a Proxy Certificate that

conforms to the profile described in this document. • A Proxy Certificate, signed by the private key of the EEC or by

another PC, is created in response to the request. During this process, the PC request is verified to ensure that the requested PC is valid (e.g., it is not an EEC, the PC fields are appropriately set, etc).

• When a PC is created as part of a delegation from entity A to entity B, this process is modified by performing steps #1 and #2 within entity B, then passing the PC request from entity B to entity A over an authenticated, integrity checked channel, then entity A performs step #3 and passes the PC back to entity B.

• Path validation of a PC is very similar to normal path validation, with a few additional checks to ensure, for example, proper PC signing constraints.

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Review of SAML 2.0

Security Assertion Markup Language:• SAML defines the syntax and processing semantics of assertions made

about a subject by a system entity.• SAML assertions and protocol messages are encoded in XML [XML] and

use XML namespaces [XMLNS].• They are typically embedded in other structures for transport, such as HTTP

POST requests or XML-encoded SOAP messages.• The SAML bindings specification [SAMLBind] provides frameworks for the

embedding and transport of SAML protocol messages. • The SAML profiles specification [SAMLProf] provides a baseline set of

profiles for the use of SAML assertions and protocols to accomplish specific use cases or achieve interoperability when using SAML features.

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SAML 2.0• The components primarily permit transfer of identity, authentication,

attribute, and authorization information between autonomous organizations that have an established trust relationship.

• The core SAML specification defines the structure and content of both assertions and protocol messages used to transfer this information.

• Assertions are usually created by an asserting party based on a request of some sort from a relying party, although under certain circumstances, the assertions can be delivered to a relying party in an unsolicited manner.

• The means by which lower-level communication or messaging protocols (such as HTTP or SOAP) are used to transport SAML protocol messages between participants is defined by the SAML bindings.

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SAML 2.0

• SAML profiles are used to satisfy issues such as Web Browser SSO profiles• Profiles typically define constraints on the contents of SAML assertions, protocols, and

bindings in order to solve the business use case in an interoperable fashion.• There are also Attribute Profiles, which do not refer to any protocol messages and bindings,

that define how to exchange attribute information using assertions in ways that align with a number of common usage environments (e.g. X.500/ LDAP directories, DCE).

• Metadata defines a way to express and share configuration information between SAML parties. For instance, an entity's supported SAML bindings, operational roles (IDP, SP, etc), identifier information, supporting identity attributes, and key information for encryption and signing can be expressed using SAML metadata XML documents. SAML Metadata is defined by its own XML schema.

• In a number of situations, a service provider may need to have detailed information regarding the type and strength of authentication that a user employed when they authenticated at an identity provider.

• A SAML authentication context is used in (or referred to from) an assertion's authentication statement to carry this information. An SP can also include an authentication context in a request to an IdP to request that the user be authenticated using a specific set of authentication requirements, such as a multi-factor authentication. There is a general XML schema that defines the mechanisms for creating authentication context declarations and a set of SAML-defined Authentication Context Classes, each with their own XML schema, that describe commonly used methods of authentication.

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SAML 2.0

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Additional Material – esMD AoR

Reference from prior AoR call materials

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Provider EntityPayer Entity

esMD Initiative Overview

PayerProvider

(Individual or Organization)

Contractors / Intermediaries Agent

Payer Internal System

Gat

eway

esMD UC 2: Secure eMDR Transmission

esMD UC 1: Provider Registration

esMD AoR Level 1Digital Identities Bundle Signatures

Certificate Authority

Registration Authority

Provider Directories

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AoR -- Phased Scope of Work

44

Level 1 – Current Focus

Level 2 - TBD

Level 3 - TBD

Digital signature on aggregated documents

(bundle)

Digital signature to allow traceability of individual

contributions to a document

Digital signature on an individual document

• Focus is on signing a bundle of documents prior to transmission to satisfy an eMDR

• Define requirements for esMD UC 1 and UC 2 Signature Artifacts• May assist with EHR Certification criteria in the future

• Focus is on signing an individual document prior to sending or at the point of creation by providers

• Will inform EHR Certification criteria for signatures on patient documentation

• Focus is on signing documents and individual contributions at the point of creation by providers

• Will inform EHR Certification criteria for one or multiple signatures on patient documentation

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Topics for Digital Identities and AoR Workgroup Effort

1. Identity proofing

2. Digital identity management

3. Encryption

4. Digital signatures and artifacts

5. Delegation of Rights

6. Author of Record

45

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Initiative Requirement Summary

Initiative Identify Proofing Digital Identity Management

Signing(Exchange Artifact) Encryption Delegation

of RightsAuthor

of Record

DS4P Org/Individual Yes Yes Yes Yes YesDirect Project Address/Server Yes Yes Yes No No

esMD Org/Individual Yes Yes Yes Yes Yes

Healthcare Directories Org/Individual Yes Yes Yes Yes No

LCC Org/Individual Yes Yes Yes Yes YesQuery Health Org/Individual Yes Yes Yes No NoTransitions of

Care Org/Individual Yes Yes Yes Yes Yes

46

Mandatory

Optional with consequences

Optional

Future Uses

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esMD RequirementsTopics UC1: Registration UC2: eMDR AoR L1 Bundle

Identity Proofing Required Required Required

Digital Credential Management

Required Required Required

Digital Signatures & Signature Artifacts

Required Required Required

Delegation of Rights* Required Required Required

Other

Characteristics of solutionNon-Repudiation

Required Required Required

Characteristics of solutionData Integrity

Required Required Required

* Required if the action of the responsible party is being represented by a third party

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Scope for AoR (L1)

In Scope • Identify Proofing as part of Non-Repudiation of

Actor Identity• Digital Credential Management required for

Non-Repudiation Actions (Signing and Delegation), Data Integrity and Encryption

• Digital Signatures and Signature Artifacts for Identity and Non-Repudiation

• Digital Credentials and Artifacts for Non-Repudiation of Delegation as required by UC1 and AoR L1

• Data Integrity requirement actions and artifacts• Encryption of PHI requirements• Interactions with External Provider Directories

Out of Scope• Interactions between:

• Payer and Payer Contractors• Provider and Agent• Payer or Payer Contractor and Gateway

• Transaction level encryption• Document level signatures and individual

contribution signatures• Defining delegation of rights within and between

Providers and other authors

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User Story / Workflow

Overall User Story Components

1) All Actors obtain and maintain a non-repudiation digital identity

2) Provider registers for esMD (see UC1)*

3) Payer requests documentation (see UC2)*

4) Provider submits digitally signed document (bundle) to address request by payer

5) Payer validates the digital credentials, signature artifacts and, where appropriate, delegation of rights

*User Stories for UC 1 and 2 have already been defined.

Workgroup will help define bullets 1) and 4)

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Sub-Workgroups

1. Identity Proofing

• Wednesday 1-2 pm• Robert Dieterle (Lead)• Proof of identity

requirements• Allowed proofing

processes

2. Digital Credentials

• Wednesday 10-11 am• Debbie Bucci (Lead)• Credential Life Cycle

(issuance, maintenance and revocation)

• Credential uses (Identity, Signing, Proxy, Encryption, Data Integrity)

• Specific use credentials (e.g. Direct)

3. Signing and Delegation

• Wednesday 2-3 pm• Robert Dieterle (Lead)• Signature and

Delegation artifacts• Workflow issues• Delegation process