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Table of Contents

Introduction

The NCI-supported caBIG program is facing a major expansion of its mission and of the community of stakeholders that it must engage. The success of the program to date has been widely recognized by numerous thought leaders, technology innovators, and program managers in the fields of biomedical computing and health information technology.  These leaders have been influenced by both the technological sophistication and the open community processes of the caBIG program, and are seeking to adapt caBIG to meet the much broader agenda of health care information management, sharing, and integration across institutions, communities of practice, and patients.

As a means towards engaging this larger community and contributing to the creation of solutions for its needs, the BIG Health Consortium was formed, a non-governmental organization that is affiliated with caBIG, but which has a complementary agenda that is focused on enabling the integration of research, care delivery, and patient-driven decision making in practical ways.  As a consequence, the institutional stakeholders associated with BIG Health Consortium extend well beyond the cancer centers, universities, and cooperative groups that make up the core NCI-funded constituencies that have participated in caBIG since its original incarnation.  The extended community thus goes beyond what is considered caBIG-proper today, and includes groups that are not yet connected to caGrid.

Background

The primary goal for this Architecture, Development, and Deployment of a Knowledge Repository and Service is to address the needs of this extended community for a scalable, decentralized infrastructure for managing and disseminating operational metadata and information models, and their associated semantic constructs.  The vision for the project is to re-imagine the caBIG technology environment as a more open and more readily extensible framework, one that can grow with less dependency on the centralized processes and systems that are manifest in the first generation of caBIG technology.  In particular, the role of the central metadata registry, the caDSR, must be redefined as a federation of metadata registries that can be instantiated and plugged into the caBIG grid or an extended community "cloud" by any qualified entity. 

The caDSR has a suite of tools and APIs that support workflows for metadata development, browsing and retrieval.  In addition, the caDSR has been adapted to support the UML model-driven development paradigm adopted by caBIG.  UML-defined information models such as those from the BRIDG project, caArray, caTissue, and others are each registered in the caDSR through conversion of the model elements into ISO11179 metadata constructs.  This functionality, and the workflows that it supports, has evolved over an 8-year period and is now quite mature.  It satisfies the current requirements for semantic representation in the current caBIG developer and user community, but it is ill-suited to serve the new requirements for decentralization and indefinite scalability in the broader health care community. The goal of this program is therefore to harvest and recycle the best elements of the first generation of caBIG metadata infrastructure, and to then incorporate those elements into a redesigned and modernized technology stack that is engineered from the start to support a federated deployment topology with far less centralized administration.

Scope

This program calls for the design and implementation of a metadata registry and model repository that can be instantiated in multiple physical locations in a federated manner, and which supports the caBIG and BIG Health community needs for operational semantic metadata management and integration.  The program must provide a number of capabilities and services:

  • Design and implementation of the ISO 11179 Edition 3 standard in a metadata repository (MDR) architecture.  The current caDSR implements Edition 2 of the standard, and the NCI has published a gap analysis between caDSR and ISO 11179 Edition 3 that will inform this effort.
  • Implementation of an information Model Repository that supports caBIG/BIG Health information model registration and alignment of models with ISO 11179 metadata elements. 
  • Extension of the metadata standard and associated workflow tools to cleanly accommodate ISO 21090 data types.   Some work has been done to represent ISO 21090 in caDSR, but a number of gaps remain.
  • Service-oriented programming interfaces that can be registered and exposed in caGrid, and which are compliant with emerging W3C standards. 
  • Tools to support an updated and revised semantic integration workflow that enables decentralized and localized additions of models and data elements. 
  • Transformation services that can traverse and extract the various semantic metadata constructs, including information models, data elements, and associated Description Logic (DL)-based terminologies.  The preferred or native format for the representations should be available through these services rather than forcing users to interpret one format through the lens of another.  Moreover, higher level services that cater to use cases for run-time semantics of consumer systems will need to be defined and implemented. 
  • Migration path from the current caDSR and associated tooling to the new MDR and Model Repository architecture.

Users and Characteristics

...

Include Page
Knowledge Repository Program Background
Knowledge Repository Program Background

Background/Scope

Include Page
Knowledge Repository Project Background
Knowledge Repository Project Background

Users and Characteristics

Include Page
Knowledge Repository Actors
Knowledge Repository Actors

Related Documentation

Include Page
Knowledge Repository Documentation Table
Knowledge Repository Documentation Table

Resources

The following is a list of documents that provide background material, requirements, and related topics:

Terms & Definitions

Term

Definition

MUST

This word means that the definition is an absolute requirement of the specification.

MUST NOT

This phrase means that the definition is an absolute prohibition of the specification.

WILL

This word means that the definition is an absolute future requirement of the specification.

WILL NOT

This phrase mean that the definition is an absolute future prohibition of the specification.

SHOULD

This word means that there may exist valid reasons in particular circumstances to ignore a particular item, but the full implications must be understood and carefully weighed before choosing a different course.

SHOULD NOT

This phrase means that there may exist valid reasons in particular circumstances when the particular behavior is acceptable or even useful, but the full implications should be understood and the case carefully weighed before implementing any behavior described with this label.

MAY

This word means that a requirement is truly optional. The developer may choose to include the item based on the needs of their design.

Use Case Level Criteria

When designing use cases, it is important to maintain a consistent approach to determining at which level use cases are placed when they are authored.  The granularity of the use case directly relates to its implementability, so maintaining a leveling scheme will insure that use cases are implemented, tested, etc. at a consistent level.  In alignment with this, we will maintain the following use case leveling criteria:

  • Global statement
    Example: manage patient's health
  • Use Case Level 0: most general, high level business process
    Example: treat this patient for cancer
  • Use Case Level 1: next level of business flow, such as inter-department level
    Example: treat this patient for cancer by using diagnostics, education, treatments, etc.
  • Use Case Level 2: specific enough to drive major model dimensions (static/information model, behavioral model, governance model, etc.) and can include some exception conditions
    Example: treat this patient for cancer by ordering these lab tests, evaluating the results, customizing a treatment or treatment plan to specifically address concerns
  • Use Case Level 3: includes details of each exchange of information, as well as assumptions about system boundaries
    Example: treat this patient for cancer by ordering these lab tests in the caEHR system
    i. find the patient, if new add patient, if not check for update
    ii. create request(s) for testing for patient, then evaluate the results,
    ii-a. read the faxed copy of the result or
    ii-b. receive notification in Provider email that a result is ready for viewing, etc...
  • Use Case Level 4: project-specific solution for exchanges detailed in use case level-3 (could be MSG, SOA, or both)
    Example:Standard Process Flow
    1. Provider Refers Patient for Cancer Treatment
    2. Provider and Patient have an encounter
    3. Provider evaluates Patient's condition, treatment plan, current statistics, requests diagnostics
    4. Provider updates treatment plan
    5. Patient is treated, outcomes documented
    6. Flow returns to any of the above steps or patient is released from cancer treatment

Assumptions and Dependencies

Usability

The user interface shall be designed for ease-of-use by the designated end-users, shall use terms common to the user's normal business environment, and shall require little to no additional training on the system. Drop down menus, Google-like searches, and tooltips should be used wherever appropriate.

Accessibility

The user interface should be accessible via a web browser.

General Assumptions

Following is a list of basic assumptions:

  • Federated Discovery Services: Knowledge Repository Services will be distributable and discoverable in a federated manner
  • Security Considerations: services and underlying data will be secured using the caBIG security architecture
  • Subscriptions/Notifications: services requiring subscription and notification functionality will be enabled by the caBIG pub/sub architecture
  • ISO 11179 Ed 3: the Knowledge Repository will comply with ISO 11179 Ed 3 specifications. See here for our analysis.
  • Ability to have non-administered items: the Knowledge Repository will provide for non-administered items in the ISO 11179 notion
  • Duplication/identification: in compliance with the Federated Discovery Services assumption, reference of data, data duplication, and unique identification of data will be handled

Dependencies

TBD

Functional Requirements

Model Services

Some basic description of model services.

ID

Requirement

Source

Release

MOS-1

The Model Service MUST support the abilities to record new model elements.

ConOps Init 1

---

MOS-2

The Model Service MUST support the abilities to record new assertions.

ConOps Init 1

  ---

MOS-3

The Model Service MUST support the abilities to record new rules.

ConOps Init 1

  ---

MOS-4

The Model Service SHOULD support the abilities to record queries.

ConOps Init 1

  ---

MOS-10

The Model Service MUST allow for the discovery of models based on querying model parts.

ConOps Init 1

  ---

MOS-11

The Model Service MAY support the federated discovery of models.

ConOps Init 1

  ---

MOS-12

The Model Service SHOULD allow the discovery of related model parts.

ConOps Init 1

  ---

MOS-20

The Model Service MUST support the comparison of model parts.

ConOps Init 1

  ---

MOS-21

The Model Service MUST support the harmonization of models through the comparison of model parts.

ConOps Init 1

  ---

MOS-30

The Model Service SHOULD support the merging of different parts of different models.

ConOps Init 1

  ---

MOS-40

The Model Service MAY support the graphical visualization of models.

ConOps Init 1

  ---

MOS-50

The Model Service MUST support the versioning of models.

ConOps Init 1

  ---

MOS-60

The Model Service MUST allow the retiring of models.

ConOps Init 1

  ---

MOS-70

The Model Service MUST allow the of updating of parts of a model.

ConOps Init 1

  ---

MOS-80

The Model Service MUST allow the deletion/unregistering of models.

ConOps Init 1

  ---

MOS-90

The Model Service SHOULD support the transformation of models.

ConOps Init 1

  ---

MOS-100

The Model Service SHOULD support the validation of models.

ConOps Init 1

---

MOS-110

The Model Service MUST support the reuse of model parts.

ConOps Init 1

  ---

MOS-111

The Model Service MUST support the entire reuse of direct copies of model parts.

ConOps Init 1

  ---

MOS-120

The Model Service MUST support the extension of model parts.

ConOps Init 1

  ---

MOS-121

The Model Service MUST allow the extension of classes.

ConOps Init 1

  ---

MOS-122

The Model Service MUST allow the extensions of model part relationships.

ConOps Init 1

  ---

MOS-123

The Model Service SHOULD allow the extension of attribute value lists.

ConOps Init 1

  ---

MOS-130

The Model Service SHOULD support the constraining of model parts.

ConOps Init 1

  ---

MOS-131

The Model Service SHOULD allow for classes to be subsetted.

ConOps Init 1

  ---

MOS-132

The Model Service SHOULD allow for attribute value lists to be subsetted.

ConOps Init 1

  ---

MOS-140

The Model Service MUST support the discovery of services related by model similarities.

ConOps Init 1

  ---

MOS-150

The Model Service SHOULD support the discovery of related documentation.

ConOps Init 1

---

Metadata Services

Some basic description of metadata services.

ID

Requirement

Source

Release

MDS-1

The Metadata Service MUST support the notion of data elements.

ConOps Init 1

  ---

MDS-2

The Metadata Service MUST allow the recording of data elements.

ConOps Init 1

  ---

MDS-3

The Metadata Service MUST allow new data element assertions to be made.

ConOps Init 1

  ---

MDS-4

The Metadata Service MUST allow for data elements to be updated.

ConOps Init 1

  ---

MDS-5

The Metadata Service MUST allow for data elements to be versioned.

ConOps Init 1

  ---

MDS-6

The Metadata Service SHOULD allow for data element business rules to be validated.

ConOps Init 1

  ---

MDS-7

The Metadata Service MUST allow for data elements to be retired.

ConOps Init 1

  ---

MDS-8

The Metadata Service MUST allow for data elements to be deleted/rolled back.

ConOps Init 1

  ---

MDS-9

The Metadata Service MUST support the discovery of reusable data element content.

ConOps Init 1

  ---

MDS-10

The Metadata Service SHOULD support the notion of data element usage information.

ConOps Init 1

  ---

MDS-11

The Metadata Service MUST support metadata to be queried by data element.

ConOps Init 1

  ---

MDS-12

The Metadata Service SHOULD support metadata to be queried by data element in a federated manner.

ConOps Init 1

  ---

MDS-13

The Metadata Service MUST support the comparison of data elements

ConOps Init 1

  ---

MDS-14

The Metadata Service SHOULD support the creation of a new data element from an existing data element.

ConOps Init 1

  ---

MDS-15

The Metadata Service MUST support the discovery of related models by data element.

ConOps Init 1

  ---

MDS-16

The Metadata Service SHOULD support the discover related metadata items by data element.

ConOps Init 1

  ---

MDS-17

The Metadata Service SHOULD support the discovery of related services by data element.

ConOps Init 1

  ---

MDS-18

The Metadata Service SHOULD support the discovery of related data element rules.

ConOps Init 1

  ---

MDS-19

The Metadata Service SHOULD support the discovery of forms related by data element.

ConOps Init 1

  ---

MDS-101

The Metadata Service MUST support the notion of value domains.

ConOps Init 1

  ---

MDS-102

The Metadata Service MUST allow the recording of value domains.

ConOps Init 1

  ---

MDS-103

The Metadata Service MUST allow new value domain assertions to be made.

ConOps Init 1

  ---

MDS-104

The Metadata Service MUST allow for value domains to be updated.

ConOps Init 1

  ---

MDS-105

The Metadata Service MUST allow for value domains to be versioned.

ConOps Init 1

  ---

MDS-106

The Metadata Service SHOULD allow for value domain business rules to be validated.

ConOps Init 1

  ---

MDS-107

The Metadata Service MUST allow for value domains to be retired.

ConOps Init 1

  ---

MDS-108

The Metadata Service MUST allow for value domains to be deleted/rolled back.

ConOps Init 1

  ---

MDS-109

The Metadata Service MUST support the discovery of reusable value domain content.

ConOps Init 1

  ---

MDS-110

The Metadata Service SHOULD support the notion of value domain usage information.

ConOps Init 1

  ---

MDS-111

The Metadata Service MUST support metadata to be queried by value domain.

ConOps Init 1

  ---

MDS-112

The Metadata Service SHOULD support metadata to be queried by value domain in a federated manner.

ConOps Init 1

  ---

MDS-113

The Metadata Service MUST support the comparison of value domains

ConOps Init 1

  ---

MDS-114

The Metadata Service SHOULD support the creation of a new value domain from an existing data element.

ConOps Init 1

  ---

MDS-115

The Metadata Service MUST support the discovery of related models by value domain.

ConOps Init 1

  ---

MDS-116

The Metadata Service SHOULD support the discover related metadata items by value domain.

ConOps Init 1

  ---

MDS-117

The Metadata Service SHOULD support the discovery of related services by value domain.

ConOps Init 1

  ---

MDS-118

The Metadata Service SHOULD support the discovery of related value domain rules.

ConOps Init 1

  ---

MDS-119

The Metadata Service SHOULD support the discovery of forms related by value domain.

ConOps Init 1

  ---

MDS-120

The Metadata Service SHOULD support the ability to create a value domain through subsetting/constraining.

  ---

  ---

MDS-121

The Metadata Service SHOULD allow value domains to be extended through the creation of new from existing.

  ---

  ---

MDS-130

The Metadata Service SHOULD support semantic transformations that would be explicitly based on value domain mapping, e.g. to the same value meaning.

ConOps Init 1

  ---

MDS-131

The Metadata Service MAY support syntactic transformations that would transform source value domain representation to target value domain representation.

ConOps Init 1

  ---

MDS-201

The Metadata Service MUST support the notion of data element concepts.

ConOps Init 1

  ---

MDS-202

The Metadata Service MUST allow the recording of data element concepts.

ConOps Init 1

  ---

MDS-203

The Metadata Service MUST allow new data element concept assertions to be made.

ConOps Init 1

  ---

MDS-204

The Metadata Service MUST allow for data element concepts to be updated.

ConOps Init 1

  ---

MDS-205

The Metadata Service MUST allow for data element concepts to be versioned.

ConOps Init 1

  ---

MDS-206

The Metadata Service SHOULD allow for data element concept business rules to be validated.

ConOps Init 1

  ---

MDS-207

The Metadata Service MUST allow for data element concepts to be retired.

ConOps Init 1

  ---

MDS-208

The Metadata Service MUST allow for data element concepts to be deleted/rolled back.

ConOps Init 1

  ---

MDS-209

The Metadata Service MUST support the discovery of reusable data element concept content.

ConOps Init 1

  ---

MDS-210

The Metadata Service SHOULD support the notion of data element concept usage information.

ConOps Init 1

  ---

MDS-211

The Metadata Service MUST support metadata to be queried by data element concept.

ConOps Init 1

  ---

MDS-212

The Metadata Service SHOULD support metadata to be queried by data element concept in a federated manner.

ConOps Init 1

  ---

MDS-213

The Metadata Service MUST support the comparison of data element concepts

ConOps Init 1

  ---

MDS-214

The Metadata Service SHOULD support the creation of a new data element concept from an existing data element concept.

ConOps Init 1

  ---

MDS-215

The Metadata Service MUST support the discovery of related models by data element concept.

ConOps Init 1

  ---

MDS-216

The Metadata Service SHOULD support the discover related metadata items by data element concept.

ConOps Init 1

  ---

MDS-217

The Metadata Service SHOULD support the discovery of related services by data element concept.

ConOps Init 1

  ---

MDS-218

The Metadata Service SHOULD support the discovery of related data element concept rules.

ConOps Init 1

  ---

MDS-219

The Metadata Service SHOULD support the discovery of forms related by data element concept.

ConOps Init 1

  ---

MDS-220

The Metadata Service MUST support the discovery of related data elements by data element concept.

ConOps Init 1

  ---

MDS-221

The Metadata Service SHOULD support the discovery of related value sets by data element concept.

ConOps Init 1

  ---

MDS-230

The Metadata Service SHOULD support the creation of a data element from an existing data element concept and value domain.

ConOps Init 1

  ---

MDS-231

The Metadata Service SHOULD support the creation of a new data element concept from an existing data element concept.

ConOps Init 1

  ---

Registry-Registry Service

ID

Requirement

Source

Release

RRS-1

The Registry-Registry service MUST support the import of content from one registry to another.

ConOps Init 1

---

RRS-10

The Registry-Registry service MUST support the export of content in a convenient data format.

ConOps Init 1

---

RRS-20

The Registry-Registry service SHOULD support the update of edited content from one registry to another.

ConOps Init 1

---

RRS-30

The Registry-Registry service MAY support the search of one registry from another.

ConOps Init 1

---

RRS-40

The Registry-Registry service MUST support content to be submitted from one registry to another.

ConOps Init 1

---

RRS-50

The Registry-Registry service MUST support the registration of content from one registry to another.

ConOps Init 1

---

RRS-60

The Registry-Registry service MUST support the updating of the registration of content from one registry to another.

ConOps Init 1

---

General Service

ID

Requirement

Source

Release

GEN-1

Services SHOULD support the notion of annotating any data with well defined concepts.

ConOps Init 1

---

GEN-10

Services SHOULD allow users to subscribe for notifications of changes to data.

ConOps Init 1

---

GEN-20

Services MUST support the notion of data reuse.

ConOps Init 1

---

Metadata Registry Tools

ID

Requirement

Source

Release

MRT-1

A Metadata Registry Tool MUST support a clinician friendly browser.

ConOps Init 1

---

MRT-10

A Metadata Registry Tool MUST support an information specialist browser.

ConOps Init 1

---

MRT-20

A Metadata Registry Tool SHOULD support a customizable browser.

ConOps Init 1

---

MRT-30

A Metadata Registry Tool MAY support a generalized portal that integrates various metadata registry tools.

ConOps Init 1

---

MRT-40

A Metadata Registry Tool SHOULD allow workflow management to support ECCF artifact creation.

ConOps Init 1

---

MRT-50

A Metadata Registry Tool MUST support an interface of browser/editing models and metadata with modeling tools.

ConOps Init 1

---


...

Related Documentation

The following is a list of documents that provide background material, requirements, and related topics:

Terms & Definitions

Term

Definition

MUST

This word means that the definition is an absolute requirement of the specification.

MUST NOT

This phrase means that the definition is an absolute prohibition of the specification.

WILL

This word means that the definition is an absolute future requirement of the specification.

WILL NOT

This phrase mean that the definition is an absolute future prohibition of the specification.

SHOULD

This word means that there may exist valid reasons in particular circumstances to ignore a particular item, but the full implications must be understood and carefully weighed before choosing a different course.

SHOULD NOT

This phrase means that there may exist valid reasons in particular circumstances when the particular behavior is acceptable or even useful, but the full implications should be understood and the case carefully weighed before implementing any behavior described with this label.

MAY

This word means that a requirement is truly optional. The developer may choose to include the item based on the needs of their design.

Assumptions and Dependencies

Usability

The user interface shall be designed for ease-of-use by the designated end-users, shall use terms common to the user's normal business environment, and shall require little to no additional training on the system. Drop down menus, Google-like searches, and tooltips should be used wherever appropriate.

Accessibility

The user interface should be accessible via a web browser.

General Assumptions

Following is a list of basic assumptions:

  • Federated Discovery Services: Knowledge Repository Services will be distributable and discoverable in a federated manner
  • Security Considerations: services and underlying data will be secured using the caBIG security architecture
  • Subscriptions/Notifications: services requiring subscription and notification functionality will be enabled by the caBIG pub/sub architecture
  • ISO 11179 Ed 3: the Knowledge Repository will comply with ISO 11179 Ed 3 specifications
  • Ability to have non-administered items: the Knowledge Repository will provide for non-administered items in the ISO 11179 notion
  • Duplication/identification: in compliance with the Federated Discovery Services assumption, reference of data, data duplication, and unique identification of data will be handled

Dependencies

TBD

Functional Requirements

Model Services

Some basic description of model services.

ID

Requirement

MOS-1

Record

MOS-2

New assertions

MOS-3

Rules/results

MOS-4

Queries/assertions

MOS-10

Discover

MOS-11

Federated query

MOS-12

Find related metadata

MOS-20

Compare

MOS-21

Harmonize

MOS-30

Merge

MOS-40

Graphical/visualize

MOS-50

Version

MOS-60

Retire

MOS-70

Update

MOS-80

Delete/unregister

MOS-90

Transform

MOS-100

Validate

MOS-110

Reuse

MOS-111

Copy

MOS-120

Extend

MOS-121

Extend classes

MOS-122

Add relationships

MOS-123

Extend attribute value list

MOS-130

Constrain

MOS-131

Subset classes

MOS-132

Subset/constrain attribute value lists

MOS-140

Find related services

MOS-150

Find related documentation

Metadata Services

Some basic description of metadata services.

ID

Requirement

MDS-1

Data Element

MDS-2

Record (no rules)

MDS-3

New assertions

MDS-4

Update

MDS-5

Version

MDS-6

Validate business rules

MDS-7

Retire

MDS-8

Delete/rollback

MDS-9

Discover reusable content

MDS-10

Usage information

MDS-11

Search/query

MDS-12

Federated search/query

MDS-13

Compare

MDS-14

Create new from existing

MDS-15

Discover related models

MDS-16

Discover related metadata items

MDS-17

Discover related services

MDS-18

Discover related rules

MDS-19

Discover related forms

MDS-101

Value Domain

MDS-102

Record (no rules)

MDS-103

New assertions

MDS-104

Update

MDS-105

Version

MDS-106

Validate business rules

MDS-107

Retire

MDS-108

Delete/rollback

MDS-109

Discover reusable content

MDS-110

Usage information

MDS-111

Search/query

MDS-112

Federated search/query

MDS-113

Compare

MDS-114

Create new from existing

MDS-115

Discover related models

MDS-116

Discover related metadata items

MDS-117

Discover related services

MDS-118

Discover related rules

MDS-119

Discover related forms

MDS-120

Create subset/constrain

MDS-120

Extend (create new from existing)

MDS-120

Semantic transformations (Explicitly based on mapping e.g. to the same Value Meaning)

MDS-120

Syntactic transformations ( Source representation to Target representation)

MDS-201

Data Element Concept

MDS-202

Record (no rules)

MDS-203

New assertions

MDS-204

Update

MDS-205

Version

MDS-206

Validate business rules

MDS-207

Retire

MDS-208

Delete/rollback

MDS-209

Discover reusable content

MDS-210

Usage information

MDS-211

Search/query

MDS-212

Federated search/query

MDS-213

Compare

MDS-214

Create new from existing

MDS-215

Discover related models

MDS-216

Discover related metadata items

MDS-217

Discover related services

MDS-218

Discover related rules

MDS-219

Discover related forms

MDS-220

Discover related data elements

MDS-222

Discover related value sets

MDS-223

Create data element from existing data element concept and value domain

MDS-224

Create new data element concept from existing data element concept

Non-functional Requirements

...

ID

Requirement

SE-1

The system must limit access to authorized individuals.

SE-10

Electronic Signatures should meet necessary requirements as described in 21 CFR part 11.

SE-20

The application will address section 508 of the Rehabilitation Act of 1973 where appropriate and reasonable.

SE-30

System developers must adhere to the caBIG™ caBIG Data Sharing & Intellectual Capital Policy and Procedures

...