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High-assurance authentication or workflow speed for CIS2 migration?

 

(@nhi-mgmt-group)
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TL;DR: 28 February 2027 shows why CIS1 to CIS2 migration is exposing duplicated identities, legacy pathways and shared-device exceptions, in Imprivata case work. Clinical access now has to stay secure and low-friction across local and national systems while CIS1 is phased out.

Editorial analysis by NHI Mgmt Group, based on content published by Imprivata: “Access to National Healthcare Systems: The deadline for action is getting closer”.

Key questions

Q: Why do healthcare identity controls fail when clinicians use shared devices and mixed systems?

A: They fail when the programme assumes a single-user, single-device login pattern.

Q: What breaks when high-assurance authentication is added without clinical workflow design?

A: The control often protects the login screen but not the work itself.

Q: How should healthcare organisations manage CIS1 to CIS2 migration without disrupting clinical access?

A: They should treat the migration as an identity governance programme, not a one-time technical swap.

Practitioner guidance

  • Map the clinician identity split Inventory where staff use separate identities for local and national systems, then document every handoff between those access domains so the migration plan reflects real clinical workflow.
  • Plan coexistence for CIS1 and CIS2 Build a phased access model that lets CIS1 applications and CIS2-native access operate in parallel until cutover, rather than forcing a single big-bang transition.
  • Validate shared-device authenticator coverage Test authentication methods on ward workstations, thin clients, mobile devices, and other shared endpoints before standardising on any one authenticator.

Bottom line: CIS1 to CIS2 migration is exposing how much clinical access still depends on duplicated identities, legacy pathways, and shared-device exceptions.

Glossary terms: Clinical Identity Access, High Assurance Authentication, Shared-Device Access, Federated Access

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This topic was modified 2 hours ago by NHI Mgmt Group

   
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(@mr-nhi)
Member Moderator
Joined: 6 months ago
Posts: 20707
 

Clinical CIS2 migration is really a governance redesign for shared access. The article shows that the migration pressure is not only about replacing one authentication service with another, but about preserving access across shared devices, roaming staff, and mixed local and national systems. That combination exposes any identity programme that was built around a one-user, one-device assumption. The practitioner conclusion is that healthcare identity governance has to be engineered around workflow reality, not abstract login models.

A few things that frame the scale:

  • 60% of healthcare organisations do not assess a vendor's security before signing a contract that grants access to protected health information, according to Ponemon Institute's 2023 Third-Party Risk in Healthcare report.

A question worth separating out:

Q: What should trusts do when CIS1 support is being withdrawn but CIS2 is not fully ready?

A: They should manage CIS1 and CIS2 as a controlled coexistence period with clear exception ownership, readiness checks, and access-path testing. The goal is to reduce reliance on CIS1 before the final removal date without forcing clinicians into unusable access patterns.

👉 Read our full editorial: CIS1 to CIS2 migration exposes clinical identity access gaps



   
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