The MSIA Submission to the Senate Enquiry on the PCEHR Bills was released yesterday.
It would be fair to say they are pretty “unhappy campers”
Press coverage appeared today.
MSIA doubts e-health record delivery deadline
The industry body argued the project lacks accountability, transparency and timely delivery.
- Chloe Herrick (Computerworld)
- 01 February, 2012 11:24
The Medical Software Industry Association (MSIA), whose members include Cerner, Cisco, iSoft and Microsoft, has delivered a scathing criticism of the National e-Health Transition Authority’s (NeHTA) handling of the government’s national e-health record project.
In its submission (PDF) to the Senate committee examining the Personally Controlled Electronic Health Record (PCEHR) Bill 2011, the industry body said issues of accountability, transparency and timely delivery still needed to be addressed.
MSIA referred to NeHTA’s recent “pausing” of the implementation of primary care desktop software at a number of the PCEHR’s lead implementation sites and said the actions had taken industry by surprise.
“No one in industry has been informed of what the issues are, when we may know the size of the problem or which of the many complex programs are incompatible with the build of the National Infrastructure,” the submission reads. “A failure to adequately inform stakeholders, be transparent, or to provide any timeline is consistent with NeHTA behaviour during the past few years.
All the details are found here:
The link to the full submission is found here:
The Executive Summary goes as follows:
Executive summary
The MSIA welcomes the opportunities that eHealth and the PCEHR provides for the medical software industry and Australia.
However, as with any large projects there have been a large number of challenges for all involved, but primarily a range of issues pertaining to accountability, transparency, and timely delivery.
Today, 24th January, an article in The Australian “E-health key trial halted by specifications glitch” caught many in the industry by surprise1. While a pause may be necessary, and a review of issues probably essential, no one in industry has been informed of what the issues are, when we may know the size of the problem or which of the many complex programs are incompatible with the build of the National Infrastructure. A failure to adequately inform stakeholders, be transparent, or to provide any timeline is consistent with NeHTA behaviour during the past few years. It does not make for trusting relationships, or inspire confidence in a way that allows industry to make decisions to invest in, and engage with processes in which NeHTA is involved.
This submission is to both provide information that accurately represents eHealth and PCEHR readiness and provides a range of recommendations for the Inquiry’s consideration.
The Recommendations are as follows:
Recommendations
The PCEHR BILL:
1. Add a more detailed description of the roles of all participants to aid understanding and uptake.
2. Commit to a date to publish “Rules” to allow adequate time for those who may be of risk of breach to be fully aware and compliant.
3. Increase Advisory group to include representation from research, secondary data and aged care experts. Ensure Advisory group reflects the 60% of health care delivery that is not provided by government or government agencies.
4. Make a provision that includes the taking of technical advice from the informatics community, Standards Australia and the software industry associations to ensure future changes and developments are appropriate, safe and timely.
5. Review the conflicts for the proposed System Operator in the various roles held :- as partial funder, system operator and as NEHTA Board Member
6. Review the ‘government furnished data’ liability issues, for example incorrect IHIs, incorrect PBS and MBS information, and incorrect AMT and SNOMED updates. Consider how the potential of such issues to act as disincentives, at worst, or to skew market and patient take up at best.
Healthcare Identifier and Patient Safety Issues
1. Action as an immediate priority, change requests to the HI Service that are deemed to have a potential clinical safety impact.
2. Action as an immediate priority, a government funded field study of AMT Mapping with at least 2 of the market-leading medication terminology vendors exchanging medication data.
3. All patient and clinical safety assessments and reports that have been funded either through NEHTA or other government agencies should be made publicly available immediately to provide confidence in the system. It seems unusual that the Australian Department of Health and Ageing has not required such reports of its manager of the PCEHR (NeHTA) to ensure the safety of the Australian public.
4. Review urgently all the issues in the MSIA White paper on the Healthcare Identifier Service and ensure changes are made to ensure the service can be used safely.
5. Review urgently the issues in the McCauley& Williams paper (Appendix 5). Consider a “consenting adults” model where software that acts in a parasitic way is tested with its “host” for all Conformance Compliance and Accreditation processes. Where such inherently unsafe software has been used there should be a post deployment review to ensure that patient safety and identification has not been compromised.
The PCEHR Program:
1. Reduce the scope of the 1 July 2012 release of the program (Release 1) by deferring elements that are not sufficiently mature or not sufficiently reviewed to ensure patient safety (for example, Australian Medicines Terminology, Health Terminology (SNOMED), Consolidated View, etc.).
2. Clearly define the scope of the national infrastructure partner relative to other software systems, including local PCEHRs and conformant repositories, to facilitate planning and investment by the software industry and healthcare providers.
3. Support the PCEHR program with sustainable, recurrent funding that supports the long-term viability of eHealth across the health sector (consumers, healthcare providers, healthcare provider organisations and technology providers). The National Change and Adoption and Benefits Evaluation Partners have provisionally identified national savings of several billion dollars a year from full operation of the PCEHR program; a modest percentage of these savings must be re-invested in the sector if the PCEHR program is to be successful.
Other Issues:
1. Make NEHTA accountable for its services and activities - NEHTA should be subject to federal FOI legislation (it is 100% funded by taxpayers and is for all intents and purposes a public entity).
2. The Auditor General (through ANAO) should conduct financial, information technology and efficiency audit of NEHTA as soon as possible.
----- End MSIA Text.
These recommendations deserve the most serious consideration by the Senate Committee. While I might personally have liked to see more emphasis on the leadership and governance issues which I believe are the ‘root cause’ of the present problems in Australian e-health the MSIA have clearly highlighted the absurd governance conflicts that surround the Department of Health Secretary as NEHTA Chair, PCEHR System Operator and Head of the Department of Health!
This full submission is worth a very close read!
David.
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