Addressing The Certifier Signature Problem In An
Electronic Death Registration System Using AVSS
8/12/98, Revised 9/3/98 and 10/15/98
PROBLEM
Recent Electronic Death Registration System (EDRS) evaluations
have revealed a less-than-enthusiastic acceptance of the Automated
Vital Statistics System/Electronic Death Registration (AVSS/EDR)
module by funeral directors. This appears to be related to the
difficulty in obtaining a certifier signature in Field 115. In
many instances the certifier signs Field 115 on an incomplete
death certificate, completes a separate medical and health data
worksheet, returns both documents to the funeral director, who
then transcribes medical and personal data onto the pre-signed
certificate.
This procedure stems in large part from the complexity of the
death registration process, which involves data gathering from
a variety of sources including the attending physician, the coroner,
and the decedent's family members. Frequently, the physician becomes
increasingly difficult to contact as time progresses. Another
factor is the difficulty in collecting accurate personal data
from family members. It is often the case that medical data can
be obtained shortly after death, but it takes some time to obtain
personal data, and, as time progresses, the likelihood of obtaining
a signature from the attending physician diminishes. These factors
may explain the motivation of funeral directors to have the attending
physician sign an incomplete death certificate.
Indeed, it is reasonable to expect the certifier to sign an incomplete
certificate since the stated legal requirements for filing a death
certificate, as printed on the reverse side of the Certificate
of Death, state that:
"The medical and health section data and the time of death
shall be completed and attested by the physician last in attendance,
or his/her designee, provided such physician is legally authorized
to certify and attest to these facts, or by the coroner in those
cases in which he is required to complete the medical and health
section data and certify and attest to these facts."
The medical and health section is identified on the Certificate
of Death by a thick border line, as is the date and time of death.
So the intent of the law may be to have the certifier attest only
to the medical section. However, it was clearly not the intent
of the law to have certifiers sign certificates having mostly
blank medical data fields, and the Handbook for Birth and Death
Registration states on Page 175 that:
"It is illegal for a physician to sign a blank certificate.
… A certification signed before the medical data is entered
is not, on its face, a 'completed form,' and the physician certifying
and attesting to the facts of death is guilty of fraud. Additionally,
anyone completing the medical data portion of the certificate
after the certifier has signed is guilty of fraud as well."
The EDRS pilot project in Santa Barbara County began on April
1, 1998 and involved five funeral homes. AVSS/EDR software
was developed by the University of California to meet the specifications
distributed by the state Department of Health Services (DHS) on
November 26, 1997. Paragraph 3.B of the EDRS Specifications state
that:
"All required data elements must be completed and record
must have passed all edits and cross field edits before certificate
is allowed to be printed."
Complying with this specification meant that a the certifier
had to wait until all data fields were available before signing
a complete Certificate Of Death. As discussed above, this proved
to be cumbersome for all five funeral directors, resulting in
a modest participation rate for AVSS/EDR that ranged from
27% to 51%, with a mean of 41%. While this could be considered
to be a successful trial for AVSS/EDR, increasing the participation
rate to nearly 100% is essential. Three possible solutions using
AVSS/EDR are described below.
POSSIBLE SOLUTION #1 (Second Pass)
Concept
One possible solution is to recognize that the certifier is
not attesting to the data fields that are not contained in the
medical and health section and to allow the official certificate
to be printed with only the medical data fields, obtain the certifier
signature, collect the personal data, and overprint the personal
fields on the signed certificate. That is, only the personal data
fields would be printed on this "second pass." Note:
AVSS/EDR currently produces the entire death certificate
from a sheet of blank paper, including the form parameters, in
a single pass.
Advantages
This solution would allow the funeral director to produce
a partially completed certificate with only medical data and present
it to the certifier on a more timely basis than a totally complete
certificate since only the medical fields would be required for
the initial printing. The personal data could be acquired and
added in a more tolerable time frame.
Disadvantages
While this solution appears to address the signature problem,
there are some risks that could compromise the integrity of an
EDRS. Moreover, it would unlikely result in 100% participation
rate and could be error-prone. The integrity of the electronic
data could be compromised since it would be more difficult to
ensure the exact agreement between what is printed on the paper
certificate and what is contained in the corresponding electronic
file.
Paragraph 3.C of the DHS EDRS Specifications states that:
"Upon approving certificate, LRD must authorize printing."
And Paragraph 3.D of the DHS EDRS Specifications states that:
"Printout limited to one (1) copy unless LRD authorizes
an additional copy."
These specifications were executed in AVSS/EDR by limiting
the printing of the official VS-11E certificate to only one copy
as approved by the LRD (Local Registration District). The approval
process consists of the LRD reviewing the electronic record, either
on a computer screen or by means of a draft copy. This process,
plus the single-pass printing requirement, ensures that the final
version of the paper Certificate of Death is identical to the
computer electronic record. If a second-pass method were allowed,
it would become more difficult to insure that the two exactly
coincide.
There is an increased likelihood of user error. For, example,
there will probably be some certifier-signed certificates that
will be spoiled during the second pass. This could be the result
of incorrect paper alignment, printer jams, or erroneous data
values for the personal fields that are printed during the second
pass. Under these conditions, it would be necessary to re-initiate
the process, beginning with the re-printing of the medical portion
and once again obtaining the certifier's signature.
Finally, Solution #1 does not mirror the current process of having
the certifier sign a nearly blank certificate and manually complete
the worksheet during a single visit. Rather, two visits might
be necessary: the funeral director would first visit the certifier
to obtain a completed worksheet, the funeral director would return
to the office to transcribe the data from the worksheet onto the
official copy as produced by AVSS/EDR, then the funeral
director would visit the certifier again to obtain the signature
on the partially-completed official copy.
POSSIBLE SOLUTION #2 (Signed Official Worksheet)
Concept
While it may not be the case that all funeral directors are
presently encouraging certifiers to sign incomplete death certificates,
it appears that most, if not all, are asking the certifier to
complete a worksheet. Since this is the primary mode of medical
information data collection, perhaps DHS should officially recognize
this fact and specify the content and purpose of the worksheet.
Therefore, another possible solution that should ease the certifier
signature problem is as follows:
1. DHS specifies the form and content of a medical data worksheet
that would require the signature of the certifier. The worksheet
would contain not only the certifier's signature, but also the
typed name and title, a new data field.
2. Worksheets would be produced by AVSS/EDR from blank
paper, so that there would be no cost to DHS or the LRD for their
production. Each worksheet would have a unique number assigned
by AVSS/EDR, i.e., the current 7-digit Access Control Number.
The funeral director would enter a minimum number of data elements
(for example, name of decedent and date of death) and print a
worksheet.
3. The partially complete worksheet would be completed by the
certifier, signed, then returned to the funeral director. This
is likely to occur very soon after the time of death.
4. The funeral director would transcribe the medical data from
the worksheet onto the draft death certificate. Any data fields
on the worksheet that were originally entered into AVSS/EDR
would be automatically available for completing the draft death
certificate.
5. AVSS/EDR would continue to function as is, except that
it would be necessary for the funeral director to fax a Draft
AVSS Record and the worksheet for LRD review before
the legal copy of the death certificate was approved for printing
or a disposition permit initiated.
6. Field 115 of the official death certificate printed by AVSS/EDR
(VS-11E) would no longer contain a signature, but would
list the certifier's name and title as collected on the worksheet,
followed by: "Signature On Worksheet #ACN" where ACN
is the 7-digit Access Control number
7. The worksheet would be attached to final copy of the death
certificate when it is sent to the LRD. The worksheet would remain
on file to serve as proof of certification.
Advantages
The primary advantage of Solution #2 is that the official
certifier signature would no longer be on the death certificate,
but on the medical data worksheet. This solution parallels the
common practice that most funeral directors use to obtain the
necessary data to complete the death certificate. Thus, it automates
the process, increasing efficiency for all participants while
also improving accountability since the certifier would sign a
completed worksheet, not an incomplete death certificate. Additionally,
every transaction would be computerized and electronic audit trails
would be maintained. Because it provides a direct and workable
solution to the signature problem, it is more likely to result
in a 100% participation rate in electronic death registration
by funeral directors; indeed, this might be a requirement for
electronic death registration participation. In most cases, only
one visit to the certifier would be required.
Using AVSS/EDR, the funeral director would pre-enter all
worksheet data fields for which there was prior knowledge, the
certifier would manually complete the remaining fields using black
ink, then sign Field 115. The funeral director would then transcribe
the medical fields into AVSS/EDR along with the demographic
fields as they become available. Draft certificates could be reviewed
as many times as necessary by all involved parties, including
the family members of the deceased, to be certain that all fields
were correct before the final copy of the death certificate is
approved by the LRD and printed by the funeral director. If the
draft death certificate did not agree with the worksheet or if
the medical data reported by the certifier were unacceptable to
the LRD, then a new worksheet could be easily re-printed with
all the current death certificate data values and returned to
the certifier for signature. This more thorough review process
is likely to reduce the need for subsequent amendments.
Disadvantages
The primary advantage to Solution #2 is also its disadvantage:
there would no longer be a certifier signature on the AVSS/EDR-generated
Certificate Of Death (VS-11E). Clearly this would be a paradigm
shift that would take some adjustment on the part of users of
certified copies: family members of the deceased, insurance companies,
and governmental agencies. A second official form for each decedent
would also increase paper storage requirements for death registration
at state and local vital records offices. There may also be questions
as to the legality of substituting the worksheet as a document
for certifying the fact of death. However, California Health and
Safety Code Section 102875, as listed below, provides for the
possibility of "an electronic signature substitute, or
some other indicator of authenticity, approved by the State Registrar
in lieu of a signature." It is entirely possible that
the proposed Decedent Medical And Health Data Worksheet could
serve as such a substitute. If not, it would be necessary to pass
enabling legislation to allow the worksheet to serve as legal
evidence of certification.
102875. The certificate of death shall be divided into two
sections.
(a) The first section shall contain those items necessary to establish
the fact of the death, including all of the following and those
other items as the State Registrar may designate:
(1) Personal data concerning decedent including full name, sex,
color or race, marital status, name of spouse, date of birth and
age at death, birthplace, usual residence, and occupation and
industry or business.
(2) Date of death, including month, day, and year.
(3) Place of death.
(4) Full name of father and birthplace of father, and full maiden
name of mother and birthplace of mother.
(5) Informant.
(6) Disposition of body information including signature and license
number of embalmer if body embalmed or name of embalmer if affixed
by attorney-in-fact; name of funeral director, or person acting
as such; and date and place of interment or removal. Notwithstanding
any other provision of law to the contrary, an electronic signature
substitute, or some other indicator of authenticity, approved
by the State Registrar may be used in lieu of the actual signature
of the embalmer.
(7) Certification and signature of attending physician and surgeon
or certification and signature of coroner when required to act
by law. Notwithstanding any other provision of law to the contrary,
the person completing the portion of the certificate setting forth
the cause of death may attest to its accuracy by use of an electronic
signature substitute, or some other indicator of authenticity,
approved by the State Registrar in lieu of a signature.
(8) Date accepted for registration and signature of local registrar.
Notwithstanding any other provision of law to the contrary, the
local registrar may elect to use an electronic signature substitute,
or some other indicator of authenticity, approved by the State
Registrar in lieu of a signature.
(b) The second section shall contain those items relating to medical
and health data, including all of the following and other items
as the State Registrar may designate:
(1) Disease or conditions leading directly to death and antecedent
causes.
(2) Operations and major findings thereof.
(3) Accident and injury information.
Another disadvantage of this solution is the possibility of
a difference in the data values on the worksheet versus those
on the death certificate. Since some of the data fields on the
worksheet might be completed manually by the certifier, the funeral
director would be required to interpret those values and key-enter
them into AVSS/EDR. This process is subject to interpretation
and key-entry errors. The likelihood of such errors propagating
from the draft death record to the official death certificate
would be minimized by oversight on the part of the LRD during
the review process. As described in Step 6 above, LRD review and
approval must be completed before the official death certificate
is printed. As with other aspects of AVSS/EDR, this places
an important responsibility on the LRD vital records staff. This
possible chance for a difference between what the certifier attests
and what is printed on the death certificate contrasts with the
larger likelihood of a disparity under current practice where
the funeral director frequently transcribes worksheet values onto
a pre-signed blank death certificate without LRD oversight. Periodic
random audits of worksheets and death certificates could establish
error rates and develop follow-up procedures to eliminate errors
at their sources. Again, this approach should be superior to the
current system where it is difficult to ascertain if there are
differences between what the certifier writes on the worksheet
and what is printed on the death certificate.
POSSIBLE SOLUTION #3 (Electronic Certifier Signature)
Concept
The two solutions above attempt to minimize the number of
visits that the funeral director must pay to the certifier. Solution
#1 could involve two visits and Solution #2 should require only
one. It might be possible, however, to design an electronic death
registration system that would eliminate all visits by means of
an electronic certifier signature. This could be accomplished
as follows by assigning encrypted Personal Identification Numbers
(PINs) to certifiers:
1. The funeral director obtains the medical data by telephone
or fax and prints a Draft AVSS Record from electronic data
stored in the Draft Death Certificate (DDC). When it is ready
for certification, the funeral director faxes a copy to the certifier
for review and electronic signature. Note: not all the personal
data fields have to be completed for the electronic signature
process to be executed. The DDC already contains a Case Identifier
(CID) that uniquely identifies a decedent and an Access Control
Number (ACN) that serves as a security key and is updated whenever
there is a change to the DDC prior to electronic signature validation.
2. A new AVSS/EDR paper form, called the Electronic Signature
Form, can also be printed. It contains electronic signature instructions
and bar-codes for the funeral director license number, the CID,
and the ACN. It is faxed to the certifier and contains a space
designated for the certifier's PIN. The Electronic Signature Form
cannot be printed until all required medical data fields are completed,
and no additional edits of the medical fields are permitted after
it is printed.
3. The Electronic Signature Office is a clearing house for processing
the PIN, which could be the LRD, but could also be a third party.
The Office accesses AVSS using special security procedures
and maintains a file of three electronic fields: certifier name
(MDNAME), certifier license number (MDLN), and an encrypted certifier
PIN. It uses AVSS/EDR to produce self-adhesive labels containing
bar-coded PINs, which are distributed to certifiers.
4. After the certifier receives the Draft AVSS Record and
associated Electronic Signature Form, s/he reviews the Draft AVSS
Record. If it is acceptable, s/he affixes one of their bar-coded
PIN labels to the Form and faxes it to the Electronic Signature
Office.
5. Upon receipt of the Electronic Signature Form, the Electronic
Signature Office scans the four bar-codes. AVSS then uses
the funeral director license number and the CID to retrieve the
electronic values for the ACN and certifier license number (the
latter is stored in DDC Field 116). It compares the electronic
ACN with the value that was bar-coded, faxed, and scanned. If
they agree, it retrieves the encrypted PIN using Field 116 and
MDLN as an index.
6. After decrypting the electronic PIN, AVSS compares that
value with the value that was faxed. If they agree, the electronic
signature is authentic and AVSS allows the official copies
of the death certificate and disposition permits to be printed,
although LRD approval according to current AVSS/EDR
procedures is still required. The MDNAME and the text "Electronic
Signature #ACN" are printed in Field 115 of the death certificate.
The value for Field 117 (Date Signed) is automatically set to
the date of signature authentication. A new DDC variable called
MDSTAT contains the status of the electronic signature process.
Advantages
The clear advantage of Solution #3 is that all visits by the
funeral director to the certifier could be eliminated. The certifier
would communicate the medical data to the funeral director by
fax or telephone, the funeral director would produce the Draft
AVSS Record and Electronic Signature Form and fax copies
to the certifier, then the certifier would add his/her preprinted
PIN bar-code label to the latter and fax it to the Electronic
Signature Office. Its staff would scan the four bar-codes that
identify the funeral director, the decedent, and the specific
electronic death certificate, and the certifier's PIN. Valid entries
for all four variables would result in authenticating the electronic
signature for the specific funeral director, decedent, certificate,
and certifier. Theoretically, this could greatly improve efficiency
and make disposition permits and certified copies of death certificates
available with the shortest possible delay.
This solution could be engineered to incorporate Solution #1 as
well. As indicated in Step 1 above, not all personal data fields
would have to be entered before the electronic signature was initiated
and validated. However, since the official death certificate is
printed only once in Solution #3, it does not suffer from the
disadvantages associated with Solution #1. Another advantage of
this solution is that it appears to be consistent with current
statute as specified in Section 102875 above. It might therefore
be implemented with less delay than Solution #2, which may require
new legislation.
Disadvantages
A disadvantage of Solution #3 is the need to establish an
Electronic Signature Office. This will require staffing to recruit
and train certifiers, create and maintain the certifier PIN file,
process electronic signature requests, and protect PIN security.
It would reduce effort on the part of the funeral director at
the expense of establishing and maintaining a new organization.
Certifiers might also find that the process would take more effort
on their part.
Solution #3 also has one of Solution #2's disadvantages: there
would no longer be a certifier signature on the AVSS/EDR-generated
Certificate Of Death (VS-11E). Again, this would take some adjustment
on the part of users of certified copies. This solution would
increase the complexity of AVSS/EDR and would make it more
difficult to program and maintain. For example, since this approach
requires that the original bar-codes be faxed twice, special programming
would be required to optimize bar-code legibility. It could increase
the amount of user training and add to the complexity of daily
LRD operations. There is also the risk that some certifiers would
find it expedient to share their PIN labels with associates. This
raises the more general question as to what incentives there would
be for the certifier to participate in an electronic signature
procedure versus simply signing a paper copy of the death certificate.
Note: The paper copy of the DDC is presently labeled "DRAFT
AVSS RECORD." It would probably be less confusing to certifiers
if it were re-labeled "DRAFT DEATH CERTIFICATE" so that
it would be clear that s/he was certifying a death certificate
and not just an AVSS record.
SUMMARY
Any of these three possible solutions would likely be an improvement
over the present AVSS/EDR approach. However, as described
above, each has its own set of disadvantages. All of these three
approaches will require a significant amount of new programming,
development, and testing. They differ considerably in the amount
of programming required so there should be careful study and consideration
of their relative merits before a decision is reached as to which,
if any, should be pursued. Beginning the development of one approach
and then deciding to pursue another should be avoided as it would
not only be expensive and wasteful of resources, but would create
unnecessary delays in the realizing the goal of optimal funeral
director and certifier participation.
In weighing the relative merits, the following attributes of an
EDRS should be considered:
Security
Authenticity
Legality
Efficiency
A secure EDRS will ensure that there are no unauthorized
activities and minimizes the chance for fraudulent use. The documents
it produces will have a high degree of authenticity so
that there can be not doubt that they represent the facts of death
by minimizing the likelihood of errors even when participants
make mistakes. Of course, it is important that the system be designed
from the ground up to conform to the legal requirements
of California's Health and Safety Code. Finally, a successful
EDRS must be easy to use and be more efficient than the
current manual system.
It is important to note that these attributes may sometimes conflict
with each other. Balancing these factors into an optimal EDRS
will take careful study and informed decision making.
PROBLEM
In an earlier document with the same title, dated 08/12/98,
the problem of obtaining physician signatures on death certificates
as part of the Electronic Death Registration (EDR) process was
described and three possible solutions using AVSS/EDR were
proposed. It is assumed here that the reader is familiar with
that document. As a result of discussions of that document by
the Electronic Death Registration System Task Force a fourth possible
solution has come to light that combines Solution #1 (Second Pass)
and Solution #2 (Signed Official Worksheet).
POSSIBLE SOLUTION #4 (Two-Part Death Certificate)
Concept
Another possible solution that appears to be consistent with
Section 102875 of the California Health and Safety Code would
be to allow the certifier to attest only to the decedent medical
and health data as a subset of the entire death certificate. This
information along with the certifier signature would be placed
on the reverse side of the AVSS/EDR Certificate of Death
(VS-11E). The medical and health data would first be printed on
an official sub-form containing only those fields and the certifier's
signature. In contrast to Solution #2 involving a worksheet, however,
all data fields would have to be completed using AVSS/EDR
before this official medical data sub-form could be printed and
then signed by the certifier: this sub-form could be called the
Certificate of Death Medical and Health Data (VS-11MHD). Following
the printing of this form, all medical and health data fields
would be locked. The funeral director would then collect the personal
data fields and produce a Draft AVSS Record as is presently
the case with AVSS/EDR. When all data fields were complete
and ready for review, the funeral director would submit the draft
record to the local registration district (LRD) for approval.
It would also be necessary to fax the signed VS-11MHD to the LRD.
Note that both the Draft AVSS Record and VS-11MHD have
a common numeric identifier (the 7-digit Access Control Number)
as well as the decedent's name, date of death, and other personal
identifiers. If all death certificate data fields were complete
and acceptable for registration, the LRD would approve the printing
of the official death certificate, which would be identical to
the present VS-11E, except that Field 115 would not contain a
signature, but the name of the certifier followed by the text:
"Signature on reverse side of original certificate."
Funeral directors would be instructed to place the signed VS-11MHD
for the particular decedent into the laser printer with the blank
side up (as is presently the case). The resultant product would
appear identical to the present VS-11E (with the exception of
Field 115), but the reverse side would contain the privacy notification,
legal requirements, medical and health data, and the certifier's
signature.
Advantages
This solution would allow the funeral director to produce
an official death certificate containing only medical data and
personal identifiers, then present it to the certifier on a more
timely basis. The more detailed personal data could then be acquired
later in a more tolerable time frame. Although there would be
two printing passes, the personal identifiers and control number
printed on both sides of the form would ensure that the final
version of the paper Certificate of Death is identical to the
computer electronic record. This is in contrast to the second-pass
method (Solution #1), where it would be difficult to ascertain
if the information printed on the second pass was associated with
the decedent information printed on the first pass. There would
also be a decreased likelihood of user error by reducing the consequences
of incorrect paper alignment. While solution #4 does not completely
mirror the current process of having the certifier sign a nearly
blank certificate and manually complete the medical worksheet,
it does resemble the current (manual) procedure of having the
certifier attest to only the medical and health data before the
personal data is obtained. This solution parallels the common
practice that most funeral directors use to obtain the necessary
data to complete the death certificate; however, it automates
the process, increasing efficiency for all participants while
also improving accountability since the certifier would sign the
completed portion of the official certificate containing the health
and medical data, not an incomplete death certificate as now frequently
occurs. In all likelihood, only one visit to the certifier would
be required.
Disadvantages
There would be a small likelihood of user error. For, example,
there is the chance that some certifier-signed certificates would
be spoiled during the second pass. There is also the possibility
that the funeral director would print the wrong decedent information
on the reverse side. Under these conditions, it would be necessary
to re-initiate the process, beginning with the re-printing of
the medical portion and once again obtaining the certifier's signature.
Also, as contrasted to Solution #3 (Electronic Certifier Signature),
a visit to the certifier would still be required. Another disadvantage
to Solution #4 is that there would no longer be a certifier signature
on the Certificate Of Death (VS-11E). It would reside, however,
on the reverse side (VS-11MHD) of the form and be available to
confirm authenticity. And, by placing the certifier signature
on the reverse side, there would not be an increase paper storage
requirements. Moreover, as contrasted to Solution #2, Solution
#4 does not have the disadvantage of possible differences in the
data values on the certified portion versus those on the official
certificate since data fields on the certified portion would have
to be completed and stored permanently in the AVSS data
base before the certifier's signature is obtained.
PROBLEM
In earlier documents with the same title, dated 08/12/98 and
09/04/98, the problem of obtaining physician signatures on death
certificates as part of the Electronic Death Registration (EDR)
process was described and four possible solutions using AVSS/EDR
were proposed. It is assumed here that the reader is familiar
with those documents. As a result of discussions of the documents
by the Electronic Death Registration System Task Force and from
reviewing a document written by Ray Wilson, dated 10/02/98, a
fifth possible solution may be possible.
POSSIBLE SOLUTION #5 (Physician Certification Line)
Concept
This solution is similar to Solution #3 (Electronic Certifier
Signature) except that there is a separate computer that is programmed
and operated by a third party which assumes the responsibility
of procuring, authenticating, and transmitting electronic signature
results to the AVSS computer in each LRD. A Physician Certification
Line (PCL) computer would poll each AVSS computer on a
periodic basis via an interactive session and obtain ASCII data
describing those electronic records that qualify for an electronic
signature. Certifiers would use telephones to access the PCL computer,
then enter their PIN and enough information from a Draft AVSS
Record that has been faxed to them to identify the individual
decedent and the specific version of certificate that is to be
certified. Electronic certification would employ speech recognition
to authenticate the certifier biometrically and a voice print
would be recorded. The electronic certification process would
result in a success or a failure and this information, along with
the original data collected from AVSS, would be returned
via an interactive session originated by the PCL computer. If
the electronic certification was successful, AVSS would
allow the funeral director to print an official copy of the death
certificate with text in Field 115 attesting to the electronic
signature. With careful planning, this solution could possibly
be made compatible with Solution #1 (Second Pass). Specific steps
are as follows:
Advantages
As with Solution #3 the clear advantage of Solution #5 is
that all visits by the funeral director to the certifier could
be eliminated. Theoretically, this could greatly improve efficiency
and make disposition permits and certified copies of death certificates
available with the shortest possible delay. As with Solution #3,
this solution could possibly incorporate Solution #1 as well.
Because Solution #5 uses biometric means to determine the authenticity
of the certifier and such methods are less vulnerable to repudiation,
it should be superior to Solution #3 in this respect.
Disadvantages
A disadvantage of Solution #5 is its complexity and the need
to program, deploy, and operate the PCL computer. It will also
require staffing to recruit and train certifiers, create and maintain
the certifier PIN file, protect PIN security, monitor daily PCL
computer electronic signature operations, and interact with funeral
directors and LRDs regarding electronic signature problems. As
with Solution #3, it would reduce effort on the part of the funeral
director at the expense of establishing and maintaining a new
organization. It is likely that certifiers would find the process
to take more effort on their part than Solution #3 and certainly
more than simply signing a death certificate. Solution #5 has
the same disadvantage of Solution #3's: there would no longer
be a certifier signature on the AVSS/EDR-generated Certificate
Of Death (VS-11E). Additionally, this solution would increase
the complexity of AVSS/EDR and would make it more difficult
to program and maintain. It would require a high degree of interface
development and synchronized data exchange between two disparate
computer systems. In instances where the electronic signature
failed it could be difficult to ascertain the reason for failure
when two complex systems are exchanging data on a nearly real-time
basis. It would be important, therefore, to clearly delineate
the responsibilities of each computer system. The task of coordinating
disparate computer systems would become even more challenging
statewide with AVSS computers in 50 or more LRDs interacting
with the PCL computer. Solution #5 could also be vulnerable to
certifier signature fraud since it might be possible for a hacker
to mimic the PCL computer if the security keys into AVSS
were compromised.
Updated October 15, 1998 by RL Williams
