The following e-mail arrived from DoHA a day or so ago. The context is that I asked DoHA for a copy of the RFT for the Provision of National Infrastructure Solution Services relating to the introduction of a Personally Controlled Electronic Health Record (PCEHR).
The tender was issued by the Department of Health and Ageing as RFT No 278/1011
What I have been sent since then have been tweaks and changes to the Tender and this specific one was Addendum Number 7.
As the e-mail was unclassified I assume it is OK to chat about the contents. This is different to the DataPak for the Tender which when I requested it - I was sent a Non-Disclosure Agreement to sign which would have basically demanded I put my first born to death if I divulged any of its contents, ideas or implications. Needless to say I decided not to sign.
The areas of the Addendum I found to be revealing were as follows:
Q7 How does the transition authority propose to ensure a viable take-up of PCEHR?
DOHA and NEHTA are in the process of engaging a national change and adoption partner to assist with this issue.
Q8 How does the transition authority propose to ensure that people are who they say they are when they register for a PCEHR userid and password?
This will be addressed in forthcoming design documents during stage 2
Q9 How does the transition authority propose to standardize the non clinical data that form part of a PCHER deployment i.e. organisation names, department names, gender, title, address, so that they are recognisable to viewers who want the details of people who have contributed to or accessed the record (central clinical register ?)
This will be addressed in forthcoming design documents during stage 2
Q10 What capability will be available for people to prevent access to parts of their PCEHR?
This will be addressed in forthcoming design documents during stage 2
Q11 Is this an opt in/opt out scheme?
As per the draft concept of operations, the PCEHR is an opt-in scheme.
Q12 Who will be the data owner and data custodian with respect to changes made to the data and will changes made by the person on their PCEHR be reflected in the source system where the data originated from?
Changes can only be made in the originating system. The PCEHR is a copy of the originating system information. Stage 2 design documents will provide further clarity.
Q13 What is the expected user experience relating to retrieval of the data (real time vs central repository), as this determines the mechanism used to build the record?
The performance of the system should not hinder the end user experience. Suppliers should provide details on how they will address performance issues.
Non-functional requirements will be established during the course of the program.
Q14 What is the latency allowed for source systems to send changed records to the PCEHR (assuming it is centralized) and how long will the PCEHR have to apply these changes?
Refer to Issue No. 13
Q15 How does the Transition Authority perceive the end-user patient will exercise control over their record and does this differ between bundles and channels? For example do the B2B channel and the indexing service have a dependency on patient approval for information sharing?
All channels will depend on the consumer access control settings recorded in the participation and authorisation service. The way that information is used will vary dependent on the channel. Further details will be provided during stage 2 of the RFT process
Q16 In relation to Bundle 2: How does the Transition Authority perceive the end-user client experience will look in the context of the various methods of personal information administration channels?
We have not described a concept of a personal information administration channel.
Q20 Has the Transition Authority formed a final view on how ‘client authentication’ needs to be performed for individuals accessing the Call Centre?
No, a final view has not yet been formed.
----- End Selective Extract.
So of a total of 26 Questions put we have, ‘we are still thinking about that answers’ to 10 with confirmation that the system is to be opt-in.
What, of course is not mentioned, is whether it will be opt-in by choice, or not, for clinicians.
Read the answers to the questions carefully and it becomes clear that the PCEHR is very little more than a concept and a few slides right now.
Just how one would respond to the RFT for an infrastructure partner in the light of the vagueness regarding just what one is getting into is pretty tricky to say the least. One would certainly offer a fixed price on anything for a very long while yet!
It is amusing to think that DoHA thinks that hiring an adoption and change management partner will address the issues around clinician adoption. It is called wishful thinking I believe!
David.
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