Thanks, Tim.

I think the difference is like the difference between the chicken and the pig when it comes to ham and eggs. The chicken is involved but the pig is committed.

By this I mean that UMA might be involved in RUFADAA but it is not essential. Each resource server can implement delegation in many ways that don't involve UMA. I see no major secondary economic benefits arising from this.

On the other hand, implementing the ACCESS delegation mandate, including the relative safe harbor for standards, can only be done with UMA or oauth.xyz or other standard protocol for delegation. The economic impact for such a mandate across the full range of personal data transfers would be immense.

Adrian

On Thu, Oct 24, 2019 at 6:40 PM Tim Reiniger <tsreiniger@gmail.com> wrote:
Eve, 

The two laws are conceptually similar in that they give legal standing to third-party custodial agents in information governance --- great developments for UMA!. But RUFADAA and the Access Act involve different agent qualifications and oversight (for example, the Access Act positions the FTC as the regulatory body while RUFADAA custodians are unregulated). The two laws also deal with different use cases. (In other words, the Access Act doesn't encompass or even overlap the RUFADAA.) 

Tim

On Thu, Oct 24, 2019 at 4:13 PM Eve Maler <eve@xmlgrrl.com> wrote:
Thanks Adrian! Tim, I wonder how this compares to RUFADAA. I suppose this would be a single federal law, for one. Any comments? (See "SEC. 5. DELEGATABILITY")



Eve Maler
Cell or Signal +1 425.345.6756 | Skype: xmlgrrl | Twitter: @xmlgrrl



On Thu, Oct 24, 2019 at 2:33 PM Adrian Gropper <agropper@healthurl.com> wrote:

On Tue, Oct 22, 2019 at 11:02 PM Adrian Gropper <agropper@healthurl.com> wrote:

Especially Section 5: Delegation. (There's a link to a nice summary at the very end of the page.) It calls for a right to specify a fiduciary agent, hopefully one that I can compile and own myself. I can imagine a law like this applying to all of our service providers above a certain size, like say 50 employees.

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Adrian
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Adrian Gropper MD

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Adrian Gropper MD

PROTECT YOUR FUTURE - RESTORE Health Privacy!
HELP us fight for the right to control personal health data.