We have just run a poll on the blog asking the following question:
Should There Be One Or Two Large Scale Pilots Of the Full PCEHR System Before National Implementation Is Attempted?
70% or respondents say absolutely and a good number more are saying ‘probably’.
The point of the question was to highlight the rather absurd approach NEHTA and DoHA are adopting to managing the risk of what is a pretty large IT project.
If you think the PCEHR is conceptually a reasonable and practical idea, which I emphatically don’t, then at the least, when implementing you should mitigate all foreseeable risks as fully as you reasonably can.
Right now we have the Wave 1 and 2 sites all beavering away on various little bits of what is planned to ultimately a completed PCEHR in the absence, as far as I know, of even an agreed standards framework for implementation - let alone a unifying technical architecture.
What we have is some high level box diagrams linked with some lines and some three minute conceptual videos explaining how it is all to work.
All this can be accessed here:
http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/content/pcehr
It seems to me there are a large number of unmitigated risks with all this right now. These include:
1. The absence of any Council of Australian Governments agreement to the shape of and continued funding of the PCEHR (or NEHTA for that matter).
2. The lack of any evidence base on the PCEHR approach to guide decision making.
3. The lack of a fully developed Governance Framework that has community understanding and support.
4. The lack of any reasonable scaled pilots of a complete working system so that the inevitable issues that arise during implementation can be addressed early and at reasonable cost. Just steaming ahead with a national implementation is both grandiose and stupid.
5. The lack of any real analysis of just what sort of adoption levels can be expected so proper provisioning of technical systems and services can be planned
6. The lack of much in the way of provider support in the absence of substantial incentives to cover the additional costs that will be borne by practitioners, State Health Systems and information providers.
7. The present lack of readiness of many of the proposed NEHTA infrastructure components and the lack of, at scale, testing of these components.
8. A lack of E-Health literate staff on a national basis to support the over-scaled national implementation.
9. A lack of any approach to the proper curation of health information in a shared, updateable clinical record environment.
10. Some considerable concerns held by some State Governments - see article from two days ago here:
http://aushealthit.blogspot.com/2011/08/victorian-government-is-not-thrilled.html
I wonder does a risk mitigation plan that addresses these issues exist? I doubt it.
I could go on for pages - but the bottom line is that you need to have implemented a full solution at modest scale to discover what works, what doesn’t and what mid-course correction might be needed.
To just rush on ahead with all this is really very unwise and potentially very wasteful.
David.
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