Today (May, 26, 2009) the National Health and Hospitals Reform Commission (NHHRC) published some responses from stakeholders to their recent supplementary paper entitled: Person-controlled Electronic Health Records (PDF 262 KB)
These submissions are downloadable from the links below:
305 - Australian Privacy Foundation - 26 May 2009
306 - Macquarie Health Corporation -26 May 2009
307 - Australian Medical Association - 26 May 2009
308 - Consumers' Health Forum of Australia - 26 May 2009
309 - Dr David More - 26 May 2009
310 - National Health Call Centre Network - 26 May 2009
311 - Brendon Wickham - 26 May 2009
313 - Microsoft - 26 May 2009
314 - Pharmaceutical Society of Australia - 26 May 2009
315 - Australian General Practice Network - 26 May 2009
316 - Office of the Privacy Commissioner - 26 May 2009
317 - Cancer Voices Australia - 26 May 2009
While I cannot really summarise all that is said there are some pretty clear themes that emerge.
First it is clear that most of those providing submissions are simply not clear exactly what is being proposed and how the proposed new record would interact with, feed or be extracted from present provider electronic health records.
Second many of the responses identify that provider EHRs are not the same thing as the PEHR and that without this area being properly addressed it is hard to see how progress can be made.
Third it is obvious that most responses are of the view that the PEHR and the provider held EHR should be seen as complementary parts of an overall national e-Health ‘system’ (for the lack of a better word)
Fourth the Privacy Commissioner provides the usual high quality and insightful critique of what is proposed and very clearly identifies a range of essentially unaddressed issues:
From Page 3 of the submission.
“However, the Office suggests there are some key issues which require further consideration. They include the:
1. implications of the proposal that consumers would be able to add information to their own person-controlled e-health record. System controls will be needed to ensure that health providers know who has entered each piece of information, and that information entered by another provider has not been altered by the consumer
2. areas that are to be covered in legislation, including safeguards to ensure that consumer access to health services, Medicare or health insurance payments is not adversely affected by the e-health system
3. processes for complaint handling and audit
4. capacity of consumers to control access to information which they regard as particularly sensitive
5. secondary uses of information, and
6. implications of the approach for equity and participation of disadvantaged consumers.”
Last the submissions from Microsoft, the Australian Privacy Foundation, the CHF and Cancer Voices Australia all raise subtle additional points – many of which are unaddressed.
In summary what is offered by the NHHRC in their proposal is nowhere nearly well enough thought out or clear and is unquestionably not ready for ‘prime time’.
The best the NHHRC document should be seen as is a discussion starter that needs to be moulded carefully on the basis of all the feedback provided here into a sensible proposal. That cannot possibly happen in the next month and so in the Final Report the NHHRC should highlight the vital nature of e-Health and the critical need of developing a coherent forward direction based on the National E-Health Strategy – taking appropriate account of the work offered here (both supplementary paper and the submissions).
Anything else would be very unwise indeed in my view.
David.
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