ACHI outlines immediate actions to improve the PCEHR
The Australasian College of Health Informatics (ACHI) has put together 30 recommendations that it says can be put into immediate action by the government to make substantial improvements to the functioning of the PCEHR.
As part of its submission on the recent Electronic Health Records and Healthcare Identifiers legislation discussion paper, ACHI has also taken the opportunity to pose questions about the broader issues raised by the Royle review of the PCEHR and whether the system complies with existing Australian and international standards.
ACHI president and adjunct associate professor Klaus Veil said the college has the view that the current implementation of the PCEHR does not realise the benefits originally sought and expected, and so has identified a number of changes and improvements that it believes are necessary if the goals originally envisaged are to be achieved.
“The college believes that updating the legislation alone will not be sufficient to get better uptake of the PCEHR, but the improvements outlined in the Royle report need to be done, as well as a number of others that we have repeatedly articulated,” Mr Veil said.
“These include focusing on the cohorts that will most benefit from the PCEHR: chronic disease, allergies, non-computer-literate people, non-English-speaking people, the socially disadvantaged, etc. This will also yield the greatest cost savings in terms of better managing 'frequent flyers'.”
While the college does not yet have a view on whether it is in favour of moving the system to opt-out, one of its recommendations is that the Department of Health (DoH) provide details of the design of the proposed trials of opt-out, including descriptions of methodology, representativeness, statistical significance and agreed success criteria.
It also calls for the department to consider mandating data breach notifications for all instances that contain unintended patient care error, and to clarify who would be liable should a misadventure occur if an individual removes clinically significant information.
Apart from opt-out, the other most commented upon section of the discussion paper revolves around governance and what the government plans to do with the establishment of the new Australian Commission for eHealth (ACeH), which was also a proposal of the Royle review.
The government is proposing to have ACeH up and running from July 2016, when the National E-Health Transition Authority (NEHTA) will be formally dissolved. In addition to subsuming some of NEHTA's work program, ACeH will take on the role of system operator of the PCEHR from DoH. The Department of Human Services will retain control of the HI Service.
The government proposes to set up a transition taskforce, which is due to be announced early in the new year.
ACHI recommends that DoH consider making data governance and mandating compliance with Australian technical standards part of ACeH's brief. It also wants to ensure that not just consumers but also senior expertise in health informatics, system architecture, networking and semantic interoperability be included in the governance of ACeH.
On questions of changing certain definitions in the PCHER Act and the HI Act – such as a clarification of 'healthcare' to also include aged care, palliative care and health-related disability – the college points out that the Australian Institute of Health and Welfare (AIHW) already provides definitions and governance for these data elements.
The AIHW also defines terms such as healthcare provider, which the college recommends the government take on board. It also suggests the government does a review of all overlapping and parallel legislation to ensure that inconsistencies in terminology and responsibility are amended.
Another area the government wants to amend is the definition of identifying information, so that in future not only can the system operator collect email addresses and mobile phone numbers in order to send emails and SMSs to consumers rather than just by post, but that it would help with identity verifications as well.
However, the college warns that the collection of more identifying information could potentially be a source for hacking and identity theft. It also wants clarification on whether there will be implications for healthcare providers who don't think the system will benefit patient care and therefore do not wish to use it.
ACHI's submission is available on its website.
Posted in Australian eHealth