Purpose: Serve as the authoritative enforcement layer for HIPAA consent and Purpose-of-Use (TPO) policies across applications, APIs, and exchanges. The Governor evaluates requests in real time to ensure that all disclosures of PHI adhere to patient directives, consent preferences, and organizational policies.
Core Capabilities
- Central Consent Repository: Consolidates consents from EMRs, portals, FHIR Consent resources, and scanned documents into a single normalized registry.
- Policy Decision Point (PDP): Evaluates each access or disclosure request based on patient consent, purpose-of-use, and applicable regulatory rules.
- Purpose-of-Use Control: Enforces Treatment, Payment, and Operations (TPO) boundaries while supporting research, public health, and legal exceptions with fine-grained policy rules.
- Event-Driven Enforcement: Intercepts FHIR, HL7v2, and document exchanges at the integration layer, filtering or blocking requests that violate consent or exceed Minimum Necessary scope.
- Just-in-Time Authorization: Provides workflows for emergency access (“break-the-glass”) and patient-directed overrides, always logged and reviewed.
Governance & Oversight
- Immutable audit of consent evaluations, including decision rationale and data disposition.
- Role-based dashboards showing granted, denied, or conditional disclosures by patient, department, or system.
- Integration with Audit Event Hub and Break-the-Glass Monitor for unified evidence and correlation.
- Policy authoring console for Privacy Officers to define, simulate, and publish consent rules with version control.
Compliance & Evidence
- Aligns to HIPAA §164.506–§164.512 (Use and Disclosure for TPO, Public Health, and Legal Purposes).
- Supports ONC 45 CFR §170.315(a)(13) (Patient Consent Management) and §170.315(d)(12) (Scope Control).
- Exports policy decisions and audit trails for OCR or internal reviews.
Dashboards & Analytics
- Trend analytics for consent denials, override frequency, and data access by purpose-of-use.
- Heat maps showing disclosure volumes by system or recipient type.
- Automated alerts for expired, conflicting, or missing consent directives.
Integration
- FHIR, HL7v2, and REST APIs for integration with EMRs, HIEs, payer systems, and third-party apps.
- Policy enforcement hooks for integration engines, API gateways, and mobile apps.
- Bidirectional sync with patient portals for consent submission and revocation.
Value
- Privacy: Centralized enforcement ensures every disclosure is consistent with consent and TPO rules.
- Compliance: Provides documented proof of lawful use and disclosure of PHI.
- Trust: Demonstrates responsible governance of patient data across all systems.