The following appeared on the NEHTA web site a few days ago, dated 22 July, 2009. To me what is important is not so much what is says, but what is missing. Maybe we could have a new version covering the issues I raise?
The original file is found here:
http://www.nehta.gov.au/component/docman/doc_download/764-ihi-consultaton-paper-qaa
While developing better responses to important questions they could also fix the typo in the link title.
“IHI Consultaton paper Q&A” is what we have now!
Q&A for Healthcare Identifiers
Setting foundations for a safe, secure and effective e-health System
The role of e-health is to provide those caring for a patient with access to the right information, about the right person, in the right place, at the right time.
E-health is essentially about delivering safe, quality patient-centred healthcare through the better management and sharing of health information, regardless of where or when healthcare is provided.
Unfortunately, communication within, between and across the myriad of private and government healthcare providers and systems has no single method of accurately and reliably identifying either the people getting healthcare, the healthcare providers or the organisations managing care.
Before Australia can create a national e-health capability it must ensure that everyone in the process – the patients, the providers and the healthcare organisations – is clearly and securely identified.
Australia’s peak body in the design and development of government e-health initiatives is the National e-Health Transition Authority (NETHA). NEHTA is a joint initiative of the national, state and territory governments tasked with leading the design of e-health initiatives, including identifiers for individuals and healthcare providers.
About Individual Healthcare Identifiers
What is an Individual Healthcare Identifier (IHI)?
An IHI is a unique 16 digit identifier that will be assigned to all Australian residents and others accessing healthcare in Australia. Each number will apply to only one person and will be used in health information records alongside the person’s name and date of birth. It is a simple, yet robust, indexing system.
Why introduce Healthcare Identifiers?
Communication of health information is a vital part of effective healthcare. The accurate identification of individuals and healthcare providers is critical in all health communication. Healthcare identifiers for individuals, providers and healthcare organisations, will reduce the likelihood of medical mix-ups and avoid information being assigned to the wrong patient or sent to the wrong service.
Using an IHI will ensure that healthcare providers are able to clearly identify the person they are treating. The IHIs will enable important health information about a patient to be more readily and securely linked with other information about that patient. This is particularly important for people who may have many healthcare providers involved in their care.
Why not use the Medicare number?
A Medicare number is not unique. Some individuals are members of more than one family and may be on multiple cards with multiple numbers. Also, not everyone who needs healthcare will have a Medicare number.
How will it work?
Healthcare providers may include an IHI in a person’s health records, along with name and current identifying information. If any healthcare information needs to be provided to another healthcare provider, such as in a referral, hospital discharge summary, pathology test or pharmacy prescription, the IHI will provide clear identification of the patient, the referring provider and the healthcare service or organisation receiving patient information.
The IHI will enable a person’s health information to be linked uniquely to them, and continue to be linked, no matter how many different health care providers they see and how many times they change address or other details.
This will improve the safety and efficiency of the care they receive.
Are IHIs needed to receive healthcare?
An IHI is not a requirement for accessing healthcare in Australia, although all Australian residents who are enrolled in the Medicare system will automatically be allocated a number. People who are not initially given an IHI will be allocated a temporary IHI when they receive healthcare.
The IHI will not alter the way in which anonymous healthcare services are currently provided. Nobody will be refused treatment if they do not have an IHI.
What do people need to do to get an IHI?
People who are enrolled for Medicare will receive an IHI automatically. Those not enrolled in Medicare will be provided a temporary IHI number when attending a healthcare service. This temporary number can be validated through the service operator (initially Medicare Australia) and will become that individual’s unique IHI. If a person already has a unique IHI number, then this temporary number can be merged into their existing IHI.
When will IHIs be allocated?
IHIs will be available from mid 2010. In the lead-up to implementation comprehensive testing will be conducted to ensure the legislation, processes and security is fit for purpose.
How will the IHI improve healthcare communication?
There are four key areas where immediate benefits will be derived through the use of IHIs:
Discharge summaries, i.e. patients’ ongoing care needs can be effectively communicated to their healthcare provider/s when they leave hospital.
Pathology Tests, i.e. patients’ will be accurately linked to their test results and their care provider.
Prescriptions, i.e. pharmacists can clearly identify the range of medications a patient may be receiving – allowing better monitoring for possible contra medications, as well as safely filling electronically lodged prescriptions.
Referrals, i.e. patient records and case history can be communicated safely to and from the referring healthcare provider and the required service or specialist.
What about the identification of doctors and clinics?
Authorised healthcare providers, healthcare centres and organisations will also be provided with unique identifier numbers. These will provide enough detail to clearly identify the individual provider, centre or organisation, include the provider’s business contact details if requested, and also operational information, such as the types of services provided.
About Protecting Privacy
Privacy is paramount in the development of legislation governing healthcare identifiers. Where current laws are applicable they are maintained. Where new laws are required they are being developed in the new legislation.
How will information be protected?
Specific Commonwealth legislation is being drafted to detail the governance, privacy and approved uses for the Individual Healthcare Identifiers. As well as this, access to the IHI and the limited information it contains, is protected by state and national privacy laws. Penalties apply if any of these laws are breached.
Who can access my IHI?
Access will be restricted to authorised healthcare providers or workers who can only use it to accurately identify an individual or information that relates to the individual. No other clinical or health related information is stored with the IHI. The information will accessible through Medicare Australia, individuals will be able to access their own IHI.
What can the IHI be used for?
The IHI is specifically designed to improve information management, both in the storage, retrieval and transfer of patient information and in communication across the health sector.
Who will store and look after IHI data?
Medicare Australia is to be the initial operator of the Healthcare Identifiers Service. As a dedicated provider of health related services, Medicare has the national infrastructure, processes and industry and community relationships needed to securely deliver and maintain the Healthcare Identifiers.
The Healthcare Identifier Service will be a separate and new Medicare business, not linked to its funding or claims for payment functions.
As a statutory agency Medicare Australia will be governed by national legislation that prescribes the scope of the functions it will perform and the privacy and security it must maintain.
About the Healthcare Identifier Consultations
Why are consultations on privacy being held?
Consultations with key healthcare and consumer stakeholders will contribute to making the legislation robust and effective – balancing the privacy of personal information with the healthcare benefits that can be gained through better sharing of health information.
How can I contribute to the discussion on healthcare identifier legislation?
People wanting to view and or comment on the discussion paper can do so at
www.health.gov.au/ehealth/consultation (TBC)
Where can I find out more about IHIs and the National e-Health agenda?
The National e-Health Transition Authority (NETHA) maintains a comprehensive website. You can get more information by visiting www.netha.gov.au .
----- End Document.
This document requires careful reading to see just how little justification is provided for this program and the scope of what is being consulted upon.
What the consultation is NOT about are questions like “do you think this is a good idea?” or “here are the range of possible ways of addressing the problem – which one do you prefer?”
We are told this identification is a problem and this is the way it will be addressed – by giving everyone in the community –and remember being in Medicare is about as voluntary as breathing – a new number. It seems it is not enough that we have a Tax File Number, a Car License Number, a Passport Number etc but that we all need yet another number!
Are there options? Then answer is yes but they are not mentioned or considered. (As an example the US National Health Information Network (NHIN) is being developed explicitly without a Unique Patient Identifier and right now it is going rather better than we are here in OZ).
See as an example:
http://www.tmcnet.com/usubmit/2009/07/22/4284824.htm
CAeHC Demonstrates NHIN-enabled Gateways Among Five California Health Information Exchanges
We are also told:
“In the lead-up to implementation comprehensive testing will be conducted to ensure the legislation, processes and security is fit for purpose.”
Since the legislation has not yet been developed, the technical shape of the system is not public, and there is no proof at all the ID is fit for its proposed purpose it would be good to have some criteria made public against which the testing will be conducted.
Better still we could be actually given proper details of the whole proposal so we could decide just what questions need to be answered!
Additionally there are no suggestions as to how those people who wish not the be enrolled can opt out of the system. If we have entered the world of compulsory Ids then the public should be allowed a serious discussion on the topic – and be told that is the case.
It is not clear from this FAQ just what the ordinary citizen can do to avoid abuse of the number by it being accessed and then used to provide demographic details to third parties (perhaps for a bribe) to potentially facilitate unwanted contact, abuse or worse.
You are also not told how much all this will cost now and into the future and what the cost benefit case is for doing this –even if you are convinced it the right thing to do.
It is also not explained just who is going to use this service, how it will be implemented to preserve privacy and just what the case is for actually using this identifier at all.
Last there is no discussion of the impact on the overall system of looking this ID up every time you go somewhere new for a health service. Given the number of services provided each year ( in the millions) – the cost of the time spent will be non trivial.
Back of the envelope let’s assume each person needs to access 3 providers in the year following introduction of the system. Let’s assume it takes two minutes to obtain and store the ID.
That comes to about 60 million look ups taking two minutes. This is 250,000 days of time spent. (120,000,000 divided by 60 = 2 Million Hours spent. Divide by 8 = 250,000 working days). Assume each working day costs $100 and we are talking $25M per annum on lookups! If there are even 10% of records needing to be updated the cost rises dramatically. You really need to be sure you are getting value for imposing such a cost on the system.
I really hope with the new era introduced by the NHHRC Report we can see a new era from NEHTA and that this sort of rubbish trying to treat the public like mushrooms will end real soon now.
David.
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