Tuesday, July 12, 2011

There Is Something A Little Odd About the Legislative Discussion Paper for the PCEHR.

In the last few days we have had the release of some consultation documents on possible legislation for the PCEHR.

The documents can be accessed from this link:


As I have read this there is one amazing oddity that has popped up.

First we know that Medicare Australia issues HPI-I to all the health practitioners it registers. (HPI-I and Individual Identifiers for Providers -as opposed to Organisational Identifiers HPI-O)

See here:


Second here is the list of provider types that can obtain an HPI-I

These include

› Chiropractic

› Dental

› Medical

› Nursing and Midwifery

› Optometry

› Osteopathy

› Pharmacy

› Physiotherapy

› Podiatry

› Psychology

See here:


In the legal discussion paper we read:

Page 23

Nominated healthcare providers

Section 4.2 of the draft Concept of Operations describes clinical documents that will provide information that can be indexed by the PCEHR system and accessed through the consolidated view10 of a patient’s PCEHR.

Most of the clinical documents described are already part of the healthcare information created in the current healthcare system, such as discharge summaries, referrals, specialist letters, and pathology or imaging reports. However, healthcare providers are proposed to have a key role in creating documents specifically for the PCEHR such as shared health summaries and event summaries. The shared health summary would contain key pieces of information about an individual’s health status, such as allergies and adverse reactions, medicines, medical history and immunisations. The event summary would contain similar information in relation to a healthcare episode and would be created when something significant happens that is important to the individual’s ongoing care.

The draft Concept of Operations proposes at 3.2.5 that an individual will be able to nominate a healthcare provider organisation, or individual healthcare provider, to be responsible for establishing and maintaining the individual’s shared health summary. An individual could only nominate one healthcare provider organisation at a time to manage their shared health summary, however it would not be essential to have a nominated healthcare provider in order to have a PCEHR.

The legislation would not describe criteria or specific functions for the role of the nominated provider, however it would provide a framework for rules and standards to which a nominated provider must comply in managing a shared health summary. These rules and standards may also relate to the authorship of other documents on the PCEHR system, such as event summaries.

----- End Extract.

Nowhere can I find any suggestion that the nominated provider has to be a medical doctor. Why on earth would this not be explicitly stated or is it intended that nurses or dentists etc. can assume the role? This section seems to leave the choice of provider type wide open.

A search of the whole document does not clarify the point as far as I can see.

If that is the case we can be and it will be a wide choice of healthcare provider types then this entire project will be still born.

Of course it may be that the reason for this is that the powers that be don’t want GPs in the role - as they may have to pay them - and so this is a cost saving measure. How silly would that be?

Now I know the doctors are a pain in the neck as far as the Health Department is concerned but really this seems to be going just a little far. No doctor is going to be relying on health summaries developed by other than other doctors - I promise!



Anonymous said...

From the requirements:

Healthcare provider: An Authorised User who is registered as a Healthcare Professional with AHPRA or the HI Service Operator and been assigned a HPI-I.

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

Isn't that what I said?


Anonymous said...

You didn't mention AHPRA. But other than that, yes, what you said. Though I think you're trying to have a dollar each way here; for what a health summary contains, why shouldn't a nurse assemble it?

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

No, I linked to the AHPRA Web site and I think the only person to do summaries is a registered doctor. Sorry. As I doctor, frankly nurses don't cut it in terms of clinical insight and ability to interpret clinical information.

Your mileage may vary as they say!


Anonymous said...

Well, let's face it - the doctors are all powerful.

They will make or break a PCEHR system. If they are not enrolled appropriately and if they are not at the centre of it then it will, as you say, be stillborn.

Witness Nicola Roxon's sudden backdown and broken promise in recent weeks in relation to her election promise that public patients on long surgical waiting lists will be transferred to and treated in a nearby private hospital.

This is not new. Minister Wooldridge suggested it as have other health Ministers since.

It seems like an excellent proposal at first glance ie. utilizing the excess bed capacity and resources of private hospitals to treat public patients and thereby cut the time many have to wait for surgery in the public sector.

So why did Nicola Roxon reverse her promise? Why have similar proposals in the past never progressed?

It's ever so simple. The doctors said 'no way'. Why? The Health Insurance Funds joined them and said 'no way'. Why?

BECAUSE - if patients thought they could just as easily get their operation through the public sector, albeit in a private hospital funded by the Government, they would rush to terminate their private health insurance. And if they did that the Health Insurance Funds would suffer, and the doctors would increasingly become public servants.

No wonder Nicola Roxon back-flipped on her election promise.

Now, as I said earlier, if you don't have the doctors onside and at the centre there will never ever be a PCEHR or anything else like it.