In case you were wondering what a the PCEHR System NEHTA has in mind is conceived to be I provide a brief extract from the late November, 2010 Concept of Operations.
On page 50 (as numbered) we read:
5.7 PCEHR-conformant repositories
The PCEHR system will consist of a range of PCEHR-conformant repositories operated at the national and regional level by a mix of public and private organisations. The PCEHR system capability will transition over time to provide access to richer clinical data stored in a range of PCEHR-conformant repositories.
The PCEHR system will consist of:
• A nationally operated repository, designed to provide a distributed set of secure highly available repositories for PCEHR records on a national basis.
This PCEHR-conformant repository will be used to ensure that there is a minimum level of health information available nationally and to support the sharing of critical health information when there is no other suitable repository available locally. It is likely that the national repository will be used to store health summaries and discharge summaries.
• Other PCEHR-conformant repositories will be accessible over time. These
repositories will typically be multi-purpose repositories that may have been designed for other purposes and now include new features to allow it to become conformant with the PCEHR system. Potential candidates include, but are not limited to:
– state, territory and regionally operated SEHRs (e.g. NT SEHR, NSW SEHR);
– Medicare Australia operated repository (e.g. for ACIR and Organ Donor Information);
– privately operated diagnostic services (e.g. repositories operated for/by Pathology and Diagnostic imaging companies);
– other sources including Australian Childhood immunisation register (ACIR), Adverse Drug Event Reporting (ADRAC), implant registers, cancer registries, breast screen registries, etc; and
– commercially operated PHRs (although this is subject to further policy review).
----- End Extract.
From other sources we know there will be an record indexing service, access control services and a template service (whatever that actually is).
What is not clear to me are the following:
1. Where are the health summaries and discharge summaries going to be sourced from?
2. Who will be accountable - and presumably paid - for keeping them current even after they have been uploaded?
3. Who will be accountable for errors in the summaries?
4. How will other non-government entities be paid for their time and trouble to populate the proposed repositories?
5. Who will fund the update of all the affected systems?
6. Who will train and support all the new e-Health users?
7. What happens if your GP does not want to share his records with the Government?
8. More important has anyone actually thought about any of this?
I note the RACGP has come out with some suggestions on e-Health Summaries. This is found here:
GP e-health summary
The RACGP is working closely with the National e-Health Transition Authority (NEHTA) to further define the core elements of the GP health summary and its application in an electronic health record. This will provide clinicians with key health information when providing care. Health information obtained through an accurate and current health summary will ensure safe and high quality care is delivered through access to the e-health summary in an electronic health record. Software specifications need to be developed to ensure the design is technically robust. The RACGP has established a group of GPs to work with NEHTA to ensure that electronic health records are integral to the management of patient care and the treatment of patients across the health sector.
These are worth a browse - if only to see just how much information is envisaged in being shared. and the possible risks of sharing any of this information with anyone without explicit patient consent - which does not actually seem to get a major mention.
The College Standards make it clear that clear consent, beyond just consent for treatment, is required for clinical information to be transferred to third parties:
See pages 12, 29 and 93 among others.
The document is found here:
This caution should have been included at the header of these summaries I reckon.
I wonder how this is actually going to managed and signified. In the UK this has been a major issue which is still not actually resolved as far as I know.
It is also clear the College sees some other issues:
04 Feb 2011
A need to clearly define the key elements of the GP health summary and its application in an electronic health record has prompted the Royal Australian College of General Practitioners (RACGP) to develop a set of seven factsheets to provide advice to general practice and their teams.
The 4th edition of the RACGP Standards for general practices requires that practices can demonstrate that at least 75 percent of their active patient health records contain a current health summary (criterion 1.7.2). To meet the requirements for a satisfactory summary, elements such as allergies and adverse reactions, current medicines list, current health problems, relevant past health history, health risk factors, immunisation, relevant family history and relevant social history need to be included. But what does 'current' or 'relevant' mean?
RACGP e-health spokesperson Dr Chris Mitchell said that there is a need to clearly define the core elements of the GP health summary as health information available through an accurate and current health summary will ensure safe and high quality care for patients.
----- End Extract.
There is a good way to go in sorting out content, accuracy, sharing and consent at the very least!
As for paying for all this some of the issues are flagged here!
If ever there was something that was not yet properly thought through, seems to not have absorbed lessons from overseas and needs a lot more consultation and work this PCEHR is it!
Time to swallow the pride and start really consulting! As the poll that will report tomorrow shows very few reckon this project - as presently conceived - is a goer of any sort.