The Aust. Information Industry Association’s (AIIA) Submission for the PCEHR Review is now available.
Here is the link.
The summary is short and sweet.
OVERVIEW
AIIA strongly supports the advancement of Australia’s ehealth agenda. In this context we support the development of an electronic health record that consumers can use to share their health related information with relevant clinicians across the health sector.
Noting the considerable investment that has already been committed to building the PCEHR the AIIA supports this important asset to drive achievement of Australia’s ehealth objectives and quality healthcare outcomes.
AIIA strongly encourages the Government to leverage this critical infrastructure in the pursuit of a more efficient, effective and patient centric healthcare system. We do not support any consideration that investment into PCEHR be abandoned. Rather we strongly believe there is scope to open the system to innovation and mainstream third party applications (products and services) of value to clinicians and patients. In this regard we believe the ICT industry has a key role in realizing the return on the PCEHR investment
----- End summary
There are then a good few pages of comments on what has gone wrong, which are pretty interesting and identify many issues.
The additional comments are relevant as well:
Additional comments
We would also make the following additional comments.
Concerns have also been raised in relation to:
· Inadequate project management disciplines to support execution of the project.
· The complexity of relationships between DOHA, NEHTA and conformance and compliance arrangements (e.g. the CCAGG) has also resulted in a lack of transparency and clear accountability. This also needs to be addressed
· The role and authority of the Independent Advisory Committee (IAC) has been ambiguous and while industry has been pleased to be involved, it has been unclear how the IAC has contributed to the PCEHR implementation process.
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All one can say about all this is that there are a huge governance issues that remain unaddressed.
The recommendations at the end are as follows.
Suggested improvements to accelerate adoption of the platform
As noted in the Overview to this submission, AIIA strongly supports the need to advance a digitally driven ehealth agenda, including the implementation of an electronic health record. This is imperative to keep pace with global ehealth developments and essential to ensuring the competiveness and sustainability of the Australian health system against the imperative of our demographics.
On this basis AIIA supports the ongoing development of the PCEHR but makes the following suggestions to drive the content and usability necessary to make it a valued product/service for clinicians and patients.
1. Improve the value of information in the PCEHR.
This will require a health care industry wide focus
on tackling high priority information domains such as medications management, shared health summaries, pathology, diagnostic imaging , specialist letters and discha rge summaries.
2. To drive consumer take up transition the PCEHR to an opt-out scheme.
This needs to be done at an appropriate time when the underlying PCEHR solutions and information content are at a reasonable level of maturity.
In the meantime continued effort is necessary to target take up by key and high use cohorts (e.g. aged, chronically diseased, newborns, indigenous). Simplification of the registration process is also strongly advised.
3. Drive increased clinical use of the PCEHR, through a combination of improved system usability and content and by adjusting other longer term levers such as linking clinical accreditation to the use of electronic health records.
4. Improve the quality, usability and scope of clinical and consumer technology applications.
This requires
- Addressing the cost and red tape associated with external developers linking applications to the PCEHR infrastructure
- Opening up repository based solutions
- Development of consumer portals to facilitate streamlined integration with PCEHR compliant solutions.
5. Implement a properly considered and sustainable commercial model for key stakeholders involved in the scheme (including government, clinicians and the IT industry).
This is necessary to stimulate innovation and drive sustainable IT investment in the national ehealth agenda.
- Opening up the PCEHR platform will allow third parties to create many different provider and consumer portals across different platforms (smartphones. Tablets, smart TVs’ T-Box, X-Box etc). The official PCEHR provider and consumer portals are obstacles to wider adoption because there cannot be a one size fits all approach to a user interface. Enabling mobile based front - end solutions that are distributed through traditional app stores also offers a mechanism for software developers to be remunerated for their innovation.
Opening up the presentation layer and allowing innovative new front end and specialised interfaces to be created will drive innovation, improve usability and increase adoption by clinicians and consumers.
6. Implement more representative and transparent governance of the PCEHR (and national ehealth) program, including greater industry, clinical and consumer representation on key governance forums and more effective engagement of jurisdictions to support implementation of the program at scale.
7. Implement a formal , transparent and authoritative change management process that is developed and executed with industry involvement.
8. Clarify the role and authority of the Independent Advisory Committee (IAC) specifically in terms of how it contributes to the PCEHR roll out and future development.
9. Strengthen key project management and communication disciplines.
In addition to the above suggestions we reiterate the need to maintain and enhance PCEHR information exchange foundations (as noted in the body of this submission)
----- End Submission.
So what the AIIA is saying is the PCEHR is a badly governed, unloved dog, needs a lot of fixing but we should continue on. I wonder who would really want that to happen? (Hint - maybe the Big End of the IT Town who can provide all the services!)
Or am I just too cynical?
David.
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