Sunday, July 17, 2011

It Looks Like The Disappearance of the Submissions on the PCEHR ConOps Was Not An Accident.

Here is the current Government page on the PCEHR.

PCEHR Draft Concept of Operations Consultation

Submissions on the Draft Concept of Operations - Relating to the introduction of a PCEHR system have now closed.

All submissions received by the closing date (7 June 2011) will be reviewed and this feedback will inform the final personally controlled electronic health record (PCEHR) system Concept of Operations document scheduled for release in August 2011.

In the interim, the Draft Concept of Operations - Relating to the introduction of a PCEHR system can still be viewed.

This document provides details on how the personally controlled electronic health record (PCEHR) system may look, what information it might contain, and how it will function and connect with existing clinical systems.

It also covers participation issues, information management, privacy and security, and matters of implementation, evaluation and consultation.

The content was shaped by the wide range of consultations which the Department of Health and Ageing (the Department) and the National E-Health Transition Authority (NEHTA) have held with stakeholders — consumer groups, health professionals, the Information and Communications Technology (ICT) industry and state and territory governments.

The PCEHR consumer booklet, e-health - have your say, describes key elements of the proposed PCEHR system, and the impact it will have on health care in the future.

You can also find out more about the PCEHR Concept of Operations process by reading the fact sheet.

Although the consultation period on the Concept of Operations has closed, it is planned that a PCEHR Legislation Issues Paper will shortly be available for public comment. The PCEHR Legislation Issues Paper identifies the legal issues which flow from the Concept of Operations and explores how these issues might be addressed within a legal framework. Watch the yourHealth website for information about the consultation process for legislation issues.

-----

The page is found here:

http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/pcehr

No mention of submissions. They were available and now they have vanisthed!

The Google Cache has not been updated in 10 days:

See here:

http://webcache.googleusercontent.com/search?q=cache:8gLG3k7S3GgJ:www.health.gov.au/internet/yourhealth/publishing.nsf/Content/PCEHRSubmissionsReceived+Submissions+%22PCEHR%22&cd=9&hl=en&ct=clnk&gl=au&source=www.google.com.au

Looks like a sudden change of mind. I wonder why?

Maybe the public were being nasty or just not compliant enough?

It is all pretty dodgy as far as I am concerned!

David.

5 comments:

Eric Browne said...

David,

I would think that amongst the 165 submissions, there would have to be some useful analysis of the PCEHR draft ConOps.
It's truly a shame that the Commonwealth lags so far behind our US counterparts in the openness and effectiveness of collaboration in e-health initiatives. It's also hard to reconcile this behaviour with, for instance, the Commonwealth's own "Government and Industry Principles of Engagement on ICT", particularly the principle of "building and maintaining an effective, cooperative relationship".
We have no idea how these submissions will be used, nor what will become of them.
Until, and unless the submissions reappear on the Your Health or NEHTA website, I will provide consolidated links to as many of them as I readily can at:
www.healthbase.info/pcehr/page5/page5.html.

Dr David More MB, PhD, FACHI said...

Hi Eric,

A search "PCEHR" Submissions from Mr Google finds a good lot.

I will e-mail my one in .pdf.

Cheers

David.

Anonymous said...

The Department of Health & Ageing say on their web site "it is planned that a PCEHR Legislation Issues Paper will shortly be available for public comment".

The best thing the AMA, MSIA, RACGP, Privacy Foundation, and everyone else can do is to make it abundantly clear to DOHA that that there will be no further submissions and comments forthcoming until the Department gets its act together and makes available for public scrutiny the PCEHR ConOps submissions for all to see.

Any further input on privacy legislation would be a complete waste of time and resources on everyone's behalf.

Anonymous said...

Anon 7:31 "make it abundantly clear to DOHA that that there will be no further submissions and comments forthcoming until the Department gets its act together and makes available for public scrutiny the PCEHR ConOps submissions for all to see."

Doesn't that defeat the purpose of even making submissions entirely? Why not have an alternative publication path such as Eric's?

Perhaps this statement might work better:

"All submissions will now be sent for consideration by DoHA and for publication by an independent third party who has no vested interest in hiding the shortcomings of the scheme from public view."

Anonymous said...

Sunday, July 17, 2011 10:16:00 PM a perfect suggestion and if DOHA is smart and genuine in its intent it will also put the submissions up on the yourhealth web site otherwise it will look plain stupid.