There is no mechanism for a user to "access" data without the data flowing between systems - at least not that would involve the interfaces/exchange mechanisms defined in FHIR or any other interoperability standard.  "ACCESS" inevitably involves data moving from one system to another.  Any access that happens for a user solely within the owning system is not covered by our standards as no interoperability is required. If we were talking about a web interface that was built into the system that owned the data, none of the Da Vinci specs would come into play because there is no interoperability interface involved.  If we're talking about a third party web interface exposing data to a user, the portion that Da Vinci deals with is how the third party web application retrieves the data for display - and that requires that the data flow from the 'owning' system to the third-party web application. Note: It is possible to have interoperability modes where rather than having the data flow to the consumer for manipulation/analysis, instead the "logic" for the analysis flows to the data owner.  However, this mode of behavior is only really relevant for DTR. In short, "no, there is no separate 'ACCESS' operation".