The following submission - among now 117 appeared quite recently.
They can be all viewed from this link.
http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/pcehrSubmissionsReceived
At the very top is this one:
Submission by the Victorian Government
This submission was provided via email and can be accessed via the following document link(s):
Having browsed the document all I can say is that there is some sanity returning to the discussion!
Similarly there is a fair bit of sense found here:
Submission by South Australia Health (SA Health)
This submission was provided via email and can be accessed via the following document link(s):
It is interesting that there was nothing from the other States and Territories. Nothing to say or wanting to chat privately. I wonder?
Focussing on the Victorian Submission they make the following points (among others) in a 16 page document - as signed by the Health Minister.
Point 1. p(age) 2
The PCEHR should have an agreed national business case endorsed by all Governments and agreed at COAG to ensure funding into the future and integration with State systems. They note (p3) that a business case was developed for the old IEHR but never endorsed by COAG.
Point 2. p2
The PCEHR does not follow the approach in the (agreed) National E-Health Strategy not being an incremental and staged approach.
Point 3. p3
The ConOps provides a request for ‘complimentary investments’, these have not been committed but it has essentially just steamed ahead regardless.
Point 4. p3
“Consideration of the proposed PCEHR by the Victorian Government, including allocation of funding, will be based on the provision of a business case for the current ConOps “ i.e. we will not play if there is not a real business case for all this.
Point 5. p3
This makes it clear there are core design elements of the proposal with are not really satisfactory.
Point 6. p3
It is not clear the PCEHR will support clinical workflow.
Point 7. p3
It is not clear the PCEHR and even the HI Service are sustainable given there is no funding approved after June next year.
Point 8 p4.
There does not appear to be an evidence base for the current approach to the PCEHR.
Point 9. p4
The IHI, HPI, NASH, Terminologies and Secure Messaging are not ready.
Point 10 p4.
None of the PCEHR has been shown to work as a whole or piloted. The Wave 1 and 2 sites are all using interim techologies
Point 11 p4.
The governance and consultation has not really been done as it should have been.
Point 12 p5.
Integration with provider systems (both hospital and primary care) needs to be better done and properly funded.
Point 13. p5.
The hospitals in Victoria are not anywhere near ready to meet the Commonwealth expectations for clinical documents. Will need major system upgrades.
Here is the Conclusion in full (p6).
8 Conclusion.
“The draft Concept of Operations provided a high level view of what the PCEHR might look like in the future but provides a limited view of how it might be realised. Further work is required on how the health system will transition from its current mode of operations to the proposed new operational model.
The Victorian Government remains supportive of working towards a robust national system of electronic health records. For this to occur, through whatever is the finally agreed model that best supports consumer and clinical priorities, there needs to be a strong business case that has the support of all governments and sufficient resourcing for a program of this scale and complexity. The business case and funding arrangements must include adequate support for the necessary change management and incentives for participation by all parties to ensure it is a sustainable and integrated part of the health system into the future. These are complex and critical issues that must be addressed in order to progress e-health in Australia and which we believe further consideration at COAG.”
I think this says it all. Rushed, unfunded, untested, overly ambitious, under consulted and lacking a business case.
Needs to go back to a proper review and planning process in my view and that, it would seem, of at least on major State Government.
Detailed comments on the document then fill up the next 10 pages for your reading consideration. Lots of important issues also raised here.
The SA submission also has a few issues worth reading about! The best one I spotted was the recognition that to actually have an audit trail that works to identify individuals in the hospital context would be a major costly upgrade in SA Public Hospitals.
Lots of important stuff here.
David.
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