Sunday, July 31, 2011

The Frog Is Slowly Boiling And Sadly It Is Not Noticing Its Inevitable Fate. It Will All End in Tears!

It is now only 11 months to go until we will all be able to register for our own Personally Controlled Electronic Health Record (PCEHR).

Additionally I am told that pretty soon we will have an announcement of which consortium has won the tender to build the technical infrastructure to have this all happen, and which will underpin the central components of the PCEHR. This will be the last major tender as the others covering such things as marketing, change management, benefits realisation and so on have recently been announced.

Of course there is a fair number of pieces still missing. These include the technical standards to be used, a revised concept of operations following all the submissions which closed a few weeks ago and any explicit definition of just what is going to be delivered July 1, 2012.

For what it is worth I agree with the MSIA as quoted here:

PCEHR targets unrealistic, say software companies

It is unrealistic to expect the government’s planned Personally Controlled Electronic Health Record system (PCEHR) to be up and running by next year, according to medical software makers.

The Medical Software Industry Association says it is a “very tight” timeframe to expect the system to be introduced by July 2012 and immediate action is needed to ensure more “appropriate” timeframes are developed.

In a submission to the consultation on the PCEHR system, (link) the MSIA criticises the government’s draft proposal which it says does not cover some key matters including how it intends to educate Australians about the benefits of the system.

More here:

http://www.6minutes.com.au/news/pcehr-targets-unrealistic-say-software-companies

I believe what we will see is what I would describe as a ‘political switch on’ of the PCEHR at the due date - much as we saw a little over a year ago with the IHI service. All fanfare and then pretty much nothing,

This issue is more than a sleeper I believe as well.

Data danger

25th Jul 2011

The blueprint on how the national e-health records scheme will be stored and managed is a minefield of medico-legal concerns, writes Leigh Parry. Leigh Parry

IN JUST one year, your patients will have unprecedented access to their medical records – not only will they be able to view their records online, but they will be able to control who sees them, and even add their own notes.

In theory, the personally controlled electronic health record (PCEHR) scheme will drive safer, more efficient and better quality healthcare – as Health Minister Nicola Roxon says, “Patients will no longer have to remember every immunisation, every medical test and every prescription as they move from doctor to doctor.”

Doctor groups are generally supportive of the scheme, which aims to address the fragmentation of medical records that exist across a vast array of different systems.

But shared health summaries, in which multiple health providers and the patients themselves will be able to contribute information, opens the prospect of an unprecedented deluge of data – and a medico-legal nightmare for GPs.

In their responses to the recently completed consultation on the blueprint, or the Concept of Operations (Con Ops), both the AMA and RACGP raised concerns about the medico-legal ramifications of the scheme.

A key concern is how patient information will be shared and interpreted.

More here:

http://www.medicalobserver.com.au/news/data-danger

It is also highly relevant that we have just (27th July, 2011) had a new statement on the PCEHR from the Royal Australian College of GPs.

The full statement is here:

http://www.racgp.org.au/AM/Template.cfm?Section=ehealthPCEHR&Template=/CM/ContentDisplay.cfm&ContentID=43401

The relevant part of the Statement is this part.

“2.6 Potential risks

There are a number of potential risks associated with the PCEHR that will require further clarification and resolution. These include:

  • The increased workload, responsibility and role of the GP as the nominated healthcare provider
  • Risk to clinical safety and fragmentation of care if the patient changes their nominated healthcare provider
  • The perception by the patient of the consumer portal as a communications channel for medical assistance and associated risk that they may not seek medical assistance as the functionality of the consumer portal increases
  • Treating a patient when faced with limited access to information within a PCEHR, such as in circumstances where the patient has chosen to suppress certain clinical documents and/or information
  • Clinical risks arising from both the quality and the volume of data which may lead to information not being complete, accurate or current
  • The medico-legal ramifications associated with the burden of maintenance placed on the general practitioner.

3.0 Conclusion

The RACGP supports the principles of a PCEHR as recommended by the NHHRC,1 however the RACGP acknowledges that there are potential risks which will require clarification prior to uptake by general practice.

The RACGP acknowledges that a PCEHR can improve access to health information, improve coordination of preventive health and health maintenance activities, and support emergency and after hours care. Core to the success of a PCEHR are access, information availability and quality, data exchange, privacy, security and trust. Patients need to trust that their privacy will be preserved and clinicians need to be able to trust the data quality which includes accuracy, completeness and timeliness. It is imperative that this mutual trust is preserved by a safe system.

A PCEHR system needs to build on the foundation of the GP e-health summary. General practitioners are the coordinators of patient care and the gatekeeper to the healthcare system. The RACGP supports the PCEHR as an e-health innovation that will reduce fragmented care and provide timely and accurate information at the point of care.

The RACGP supports the sharing of a medical record that:

  • Supports a person-controlled electronic health record
  • Contains reliable and relevant medical information
  • Aligns with clinical workflows and integrates with clinical software
  • Aligns with National Privacy Principles and the overarching National E-Health Transition Authority (NEHTA) Privacy Framework and Security Access Framework
  • Is governed by a single national entity
  • Is fully funded by governments and supported by appropriate incentives, education and training.”

This all makes for the most qualified support and politest possible this is really going to cost you and needs a great deal more work you’ will ever see. Frankly, from an information management perspective, I simply do not think what the College is asking for is actually doable! As far as cost, it isn’t in the budget and won’t be cheap.

I think it is probably time to put a stake in the ground on all this. Essentially I think we are all being treated like the unfortunate frog and we will be frog’s legs before we notice what an enormous con the spin being put out by NEHTA and DoHA is. The con really has two parts. The first is the claim that anything useful will be delivered in eleven months and the second is that the PCEHR is the optimal model to progress e-Health in Australia. They will fail on two out of two.

As I wrote in an e-mail to a mate:

“We need to be clear this whole (PCEHR) thing emerged as a 'thought bubble' from a single NHHRC member (who is an enthusiastic e-health amateur) in 2009 and has been grasped by NEHTA and DoHA as a way of 'doing something' without any real review or cost benefit analysis of the proposal. All that was done was to warm over their older NEHTA IEHR business case and then suggest the same benefits would flow - which was, and is, just wrong, as they well know.

I am 100% sure that in 2 years those that make this clear, and that the plan is conceptually deeply flawed, will have quadrupled their credibility by being the clearest in pointing out how badly flawed all this is. Equally those that are spruiking it are going to look pretty dumb.

This all reminds me of the times when many thought you could not do without slavery, that evolution was just a theory and when it was obvious that women should not vote - until eyes opened and we can now understand what nonsense was being foisted on us.”

It is time for DoHA to explain just how the technical, standards, adoption, consent and medico-legal issues will be addressed in credible detail.

It is also time for DoHA to explicitly explain just how much will be delivered on July 1, 2012 and, even more important, if and when the authorisation for ongoing funding of the project and NEHTA is going to be announced. This ignores the huge extra that will be needed to get the GPs on board (100s of millions I estimate).

This whole disastrous project is being given far too much support by all sorts of vested interests as increasingly e-Health experts and clinicians are seeing just how silly the whole thing really is!

We have already seen some stirrings of political concern about all this and , unless some real review is undertaken to test out the practicality and viability of the PCEHR plan, this will only get stronger.

David.

3 comments:

Anonymous said...

It appears that Nehta and Doha are going to push on, raising the stakes as they go. Lets hope the fall that follows leads to a total change in approach to eHealth and not another rearrangement of the deck chairs on the Titanic.

The issue is that they will claim success in a "Yes Minister" kind of way. I mean we all have identifiers so that's been a success hasn't it??

The total lack of accountability is an enormous issue here. The PR department of Nehta are performing at a high level, shame about the rest of the organization.

Anonymous said...

The issue is that at some point Political correctness will meet reality and on that day it will not be pretty.

Nehta and Doha have made the PCEHR the only game in town wrt funding and so many experts income is dependant on funding and so many organizations are looking for their slice of the pie that we have a perfect setup for the emperor has no clothes scenario.

We are talking eHealth and software and it is unforgiving when the rubber hits the road. They seem to be keen to dump Clinical Decision Support as they know what is proposed won't cut for that and that is where the real long term value is.

I am not sure if they have an escape plan, maybe they just assume that their pain will end with the next election so they may as well party now knowing that what they are building always has been a sandcastle in the air and they may as well ride the gravy train for a little longer. No serious informatics expert would back what is planned but when they have bills to pay having the moral backbone to speak out appears to be lost. Suppression of alternative opinion and putting all the publics eggs in this basket is crazy and when this is eventually looked at in retrospect it will not look good for many of these "Yes Men". I see it all the time, yes we know its fundamentally broken but we have to make it work somehow because the people who decided on this are untouchable. They should not be untouchable when they are spending taxpayers (borrowed) money.

Anonymous said...

"because the people who decided on this are untouchable."

and permit me to add ....... not only are they untouchable, but they were also naive and easily conned by expert con merchants who saw them in the distance and made a beeline for their honeypot. Come into my parlor said the spider to the fly ..... and in they came, hook, line and sinker.