Quote Of The Year

Timeless Quotes - Sadly The Late Paul Shetler - "Its not Your Health Record it's a Government Record Of Your Health Information"

or

H. L. Mencken - "For every complex problem there is an answer that is clear, simple, and wrong."

Tuesday, June 26, 2007

The NEHTA Review – I Sure Hope it Helps!

Yesterday it was announced that the Boston Consulting Group have been engaged to review NEHTA. The full text of the release is as follows:

BCG wins tender to conduct the NEHTA Review

25 June, 2007. The NEHTA Board today announced that the Boston Consulting Group (BCG) has been selected via open tender to conduct the NEHTA Review.

NEHTA Ltd was established in July 2005 and funded jointly by all federal, state and territory governments for a three-year period to accelerate e-health in Australia. NEHTA’s constitution requires Directors to commission an independent review of NEHTA’s future direction two years after the company’s formation.

BCG is due to commence the review process in July.

“I am confident that BCG has the capacity to conduct an independent and thorough review of NEHTA. They have a superior understanding of the e-health environment in Australia and overseas and have the knowledge to comprehensively review the work undertaken by NEHTA to date,” said Uschi Schreiber, NEHTA Chair and Director-General of Queensland Health. “BCG’s team also has the capability to succinctly consider and evaluate any ongoing role for NEHTA beyond 2007/08 and the benefits and risks of alternate governance arrangements under which NEHTA, or its successor, could operate.”

The review will address the effectiveness of NEHTA in meeting its objects, as set down in the constitution, including whether these objects remain valid and appropriate.

BCG will gather information on NEHTA’s operations from:

· NEHTA and its Directors;

· Jurisdictions;

· Key stakeholders; and

· Independent research.

In addition, the review will consider the future direction for e-health reform and the most appropriate vehicle(s) for future directions, including the future role for NEHTA Ltd, or similar organisation.

There will be the provision for stakeholder input into the review. Contributions to the review can be forwarded by email to nehta_review@bcg.comThis e-mail address is being protected from spam bots, you need JavaScript enabled to view it .

The findings of the review will be provided to the Directors in the first instance. A General Meeting of Members will be called within two months of the review being completed, to consider and vote on the future of NEHTA. The review process is planned to conclude before the end of 2007.

----- End of Release.

Well this is a good thing to be happening as the BCG is a consulting group of considerable reputation and expertise.

I do have, however, a number of concerns.

First, given the study is to commence in July and be completed before the end of 2007, I am concerned that the time frame may be some-what compressed. The last thing we all need when “the review will consider the future direction for e-health reform and the most appropriate vehicle(s) for future directions, including the future role for NEHTA Ltd, or similar organisation” is to take inadequate time to address all the issues.


I am quite concerned the time frame allowed for the review (looking like being only 4 months or so actual elapsed work time) may not allow for an in-depth review of all the aspects of Australian e-health and ensure we are not yet again in the situation where we are essentially starting again without having learnt all the lessons of the past decade. The learning aspect of this engagement is vital. We don’t have an infinite number of chances to get this right!


Second, given that NEHTA is the organisational and operational outcome of a BCG consultancy conducted three years ago (2004), I think I would have preferred someone else to review the outcome of the BCG work some three years later. (Booze Allen Hamilton or McKinsey spring to mind).


Third I am concerned at just what will be defined as “key stakeholders”. At the very least the process must be conducted in a transparent and consultative way and includes gathering the views of all relevant parties including consumers, the MSIA, Health IT Vendors, the AIIA, AHIC, medical, nursing and like colleges and organisations and Academia as well as the Jurisdictional Sponsors of NEHTA. One gets the sense from the press release this level of breadth is not actually contemplated.


Fourth, the lack of commitment, in the press release, to public release of a draft document for comment before the document and recommendations is finalised is of some concern as it the statement that "The findings of the review will be provided to the Directors in the first instance. A General Meeting of Members will be called within two months of the review being completed, to consider and vote on the future of NEHTA. The review process is planned to conclude before the end of 2007." Consideration of the review by the public does not seem to be contemplated in this. If we are to have another report done in secret by consultants bound by ‘commercial in confidence’ constraints it will be a serious travesty.


Fifth, one is really forced to ask why the actual “Terms of Reference” for the BCG engagement are not included with the release. Not sure that presages a good outcome.


Sixth, it needs to be realised this is a Board who has selected a consultant on the basis of an evaluation conducted by its staff and executive. It seems to me there is already a major conflict of interest involved as it would be extremely unlikely – although possible I guess – that the Board, unaided by NEHTA staff made the selection.


Seventh, I see no commitment in the Press Release to the full outcome of the review being made public. One certainly hopes it will be so the relevant lessons can be learnt by all!


Eighth, I hope a significant part of the review will be based on what was, and was not achieved, based on the objectives set out in the 2004 recommendations.


Last I also note the press release does also not make clear just what interaction there will be between the review team and AHIC in the determination of forward e-health strategy."


Further commentary on the NEHTA review can be found in an older posting:


Here We Go Again!



We all have to be concerned that the BCG will find themselves reporting to the people who would see a bad report as an existential threat. The governance of the project should really be made public so we can all be re-assured such a problem does not exist.


As an experienced consultant, who has worked in the real world, I know only too well the subtle pressures a client can exert to get the report they want – especially when it is the client who will pay the bill. I know the BCG are and will be well aware of all these risks and issues but it would be good to know they have been properly protected organisationally from such pressures and risks before the project starts. Ideally some-one other than NEHTA should be responsible for accepting each of the deliverables and agreeing to payment.


We can all await events and prepare submissions as suggested in the release!


David.


5 comments:

Anonymous said...

No-one should cast aspersions on BCG for they are a highly reputable consulting group, as you have rightly said. Despite this your concerns are valid in every way.

Examining the points you have made you have scored 100%.

1. BCG will consider (= determine) the future direction for e-health reform in Australia.

2. BCG is being seriously compromised by being contracted to review the outcome of its three year old consultancy.

3. The press release does not indicate the review will be open, transparent and consultative of all key stakeholders.

4. No public release of a draft document for comment before finalising the review document and recommendations will totally undermine the validity of the consultancy

5. The Terms of Reference need to be all encompassing.

6. In the interests of probity the Board needs to confirm publicly that none of NEHTA Executive staff were involved in any way in the selection process of the consultancy firm undertaking the review.

7. If the full outcome of the review is not made public its value will be seriously compromised.

8. The Terms of Reference of the review should include the objectives set out in the 2004 recommendations.

Anonymous said...

If the Board of NEHTA insist on using BCG they should contract PWC or McKinsey into the loop to ensure probity is rigidly enforced.

Anonymous said...

David More points out that it will be important for the consultants conducting the review to gather "the views of all relevant parties including consumers, the MSIA, Health IT Vendors, the AIIA, AHIC and Academia". It will also be vital (I believe) to gather the views of medical professional organisations including the RACGP, AMA, AGPN and ACRRM, who represent the actual end users of electronic health information systems, for their opinions and feedback abou whether NeHTA has fulfilled its mission.

Dr David G More MB PhD said...

All,

I certainly agree with both suggestions. Leaving out the medical professional organisations and the all the learned colleges was an oversight.

David.

Trevor3130 said...

Mark Ragg, on behalf of Queensland Health, has published Caring for our health (A report card on the Australian Government's Performance on Health Care). I cannot find a word about electronic health records. Is this another policy blind spot, another lost opportunity to get EHR in the Top Ten?

AIHW followed closely with a disclaimer that Ragg's report had anything to do with this sub-branch of the Australian Government. It's hard to find any reference to the central importance of electronic health records in any of AIHW's subject areas.

On Tuesday June 26th, the Victorian Government's Drugs & Crime Prevention Committee continued its
Inquiry into Misuse/Abuse of Benzodiazepines and Other Pharmaceutical Drugs.
Two witnesses gave lengthy and well-informed expositions on quite different aspects of the problem, but they both brought out issues highly relevant to EHR. Some of the points were:

- no means to trace private (non-PBS) prescriptions

- are there any warnings in GP software about overuse of drugs of
dependence?

- the data available at the Prescription Shopping node of the PBS is at least 6 weeks behind.

- the people at the PBS call centre often describe how they have to log out of one system, and 'wake up' another

- there is no collation of prescribing records between pharmacies

- when pharmacies change hands (eg the current switches from Amcal to Pulse) records are lost, and different business models are brought in

- what is the status of electronic passage of scripts from prescriber to pharmacy?

- again, where is the medication history database - IT DOES NOT EXIST

- is there any progress toward a Unique Patient Identifier?