Sunday, August 14, 2011

PCEHR ConOps Submissions Reviewed And Why The States Are Not Happy With the PCEHR.

A week or so ago I came upon a cached copy in Google of this recently created report.

You can read that blog here:

Over the last few days I have been sent the full .pdf file of that report. I can't find it on the web but it does not appear secret so here you go!

You may down load the file from here (about 850k).

It is interesting to note the planned process for the development and finalisation of the PCEHR ConOps.

3 Process review

3.1 Overview of the ConOps submissions review process

The development and finalisation of the PCEHR ConOps document has three phases:

3.1.1 Phase one: initial development of the ConOps

The content in the draft ConOps was shaped by the wide range of consultations which DoHA and NEHTA have held with stakeholders — consumer groups, health professionals, the Information and Communications Technology (ICT) industry and state and territory governments. These consultations are described in more detail in Appendix A of the Draft Concept of Operations: Relating to the introduction of a personally controlled electronic health record (PCEHR) system.

The draft ConOps document was released for public consultation on 12 April 2011. Public submissions were sought as part of this process. The original closing date for accepting submissions was 31 May 2011. The closing date was subsequently extended until midnight on 7 June 2011 in response to the high level of interest shown in the ConOps consultation process. Submissions on the draft ConOps were accepted via the following channels:

  • Public comments submitted via the website
  • Electronic documents provided by email
  • Hardcopy documents provided by post

3.1.2 Phase two: review and analysis of submissions on the draft ConOps

A register was assembled by DoHA of all the submissions that were received on the draft ConOps. An initial analysis of all of the submissions was undertaken. Based on this initial analysis, each section of all of the submissions was then subject to a more detailed analysis by multiple reviewers.

A triage process was then undertaken to group, sort and prioritise the content of the submissions. Following this process a number of internal working groups were formed of subject matter experts to focus on specific areas to identify the key themes and points of interest raised in the submissions. An independent review of the key themes and points of interest raised in the submissions was concurrently undertaken in parallel with these working groups.

This information was then synthesised and consolidated with the information gained during the initial analysis of the submissions to produce this report.

3.1.3 Phase three: update and finalisation

The draft ConOps document will be revised to incorporate changes based on the submissions process, and further discussions with key stakeholder groups,

including individuals, healthcare providers, the ICT industry and state and territory governments.

The ConOps document is expected to be finalised in August 2011. This document will incorporate all changes that have been made to the ConOps based on the feedback received as part of the submissions process.

Where applicable, information and suggestions from the submissions on the ConOps will be incorporated into design work by the National Infrastructure Partner, and will also be included as part of the work being undertaken by the National Change and Adoption Partner for the PCEHR program.

----- End Extract

The main point here is that we should be seeing the final version of the ConOps by the end of August 2011. I suggest those interested read the full document that is linked above - a summary of which is provided in my earlier blog.

However, an even more interesting quote is found here in Section 1.0 of the document.

1 Introduction

In the 2010/11 Federal Budget, the Australian Government allocated $466.7 million for the development and implementation of a Personally Controlled Electronic Health Record (PCEHR) system. The Draft Concept of Operations: Relating to the introduction of a personally controlled electronic health record (PCEHR) system (ConOps) was initially based on a framework for a national electronic health record system agreed by the Australian Health Ministers Conference in April 2010. The ConOps document was further developed and refined through an extensive consultation process that included consumers, healthcare providers, the information and communication technologies (ICT) industry, and government organisations. The draft ConOps was made available to the public on 12 April 2011 for consultation and comment.

Note the bold part of the comment.

I thought I would go and have a look and see what was actually agreed:

Here is the COAG and AHMC reference:


COAG noted the importance of continuing to work towards a National Individual Electronic Health Record system and agreed to prioritise discussions over the coming months to move towards the implementation phase.

----- End Extract

The relevant meetings of AHMAC are found on this page:

Here is the relevant April 2010 entry.

22 April 2010 - AHMC Communique

Australian Health Ministers from the Commonwealth and all States and Territories met in Perth today and discussed a range of health issues including the ground breaking national health reforms negotiated at COAG this week.

Sadly there is no mention in these documents of e-Health.

The only mention that is close seems to be this one from November, 2009 which only talks about the HI Service:

National e-health system one step closer

Health Ministers today affirmed their commitment to the introduction in 2010 of national healthcare identifier numbers and agreed to release for further consultation draft legislation for establishing the healthcare identifiers.

Ministers considered feedback from the first phase of public consultations held in July-August 2009. Following these consultations and feedback, further work has been done on the identifiers to clarify and strengthen patient privacy. Ministers have now agreed:

§ the legislative framework will limit the use of healthcare identifiers to health information management and communication purposes as part of delivering a healthcare service;

§ healthcare identifiers will be underpinned by effective national privacy arrangements, protecting health information wherever it is associated with healthcare identifiers, regardless of whether the information is held by a public or private organisation;

§ the Healthcare Identifiers Service (HI Service) will have an appropriate governance framework with transparent and accountable processes;

§ penalties will apply to the misuse of healthcare identifiers; and

§ to review the implementation of the healthcare identifiers after a period of two years.

Healthcare Identifiers are unique numbers that will be given to all healthcare providers, healthcare organisations and healthcare consumers. These unique numbers will provide a new level of confidence when communicating patient information between the myriad of private and government healthcare providers and systems. The identifiers are an important building block for the eventual introduction of a patient controlled Individual Electronic Health Record.

The legislation to establish the Healthcare Identifiers will be introduced to the Federal Parliament in the Autumn 2010 sittings.


It is now clear why there is some angst on the part of State Governments. Essentially the PCEHR has just been ‘dropped-on’ them with no funding and as they say ‘they don’t like it’

See here:,states-demand-federal-funding-for-e-health-record.aspx

States demand federal funding for e-health record

James Hutchinson

State costs likely above $467 million capital spend.

Australia's State governments have called for federal funding to help implement the national e-health record by July 1 next year.

The Victorian Government in particular has accused the Department of Health and Ageing (DoHA) of failing to discuss Federal Government plans with state and territory governments ahead of implementation, according to a submission released this week.

and here:,feds-push-back-on-state-e-health-funding.aspx

Feds push back on state e-health funding

James Hutchinson

States want more money for e-health record integration costs.

The Federal Department of Health and Ageing has denied states and territories additional funding to implement its $467 million personally-controlled electronic health record (PCEHR) project.

The lack of federal funding would require individual state governments to front up their own money to establish infrastructure not directly tied to the rollout of the national e-health records.

"No additional PCEHR funding is expected to be allocated to states or territories," a department spokesman said.


So we have a real stand off here. States won’t move without extra funds and the Commonwealth says there are no extra funds. It really is astonishing - and incompetent - that a program of this scale which inevitably involves the states in all sorts of ways was not agreed by COAG before it was commenced. Really bizarre!

It is, of course, worth noting that the ConOps really amounts to a wish list rather than what will be delivered by the National Infrastructure Partner. DoHA and NEHTA will take what they are offered. It is likely that, even then, the political deadlines they are working to will be made a nonsense of by reality!

We can all watch with interest as this plays out!



Anonymous said...

Private healthcare providers have also been totally excluded from the planning process.

It is an absolute disgrace.

Anonymous said...

It's time governments stopped trying to implement software and just insisted on compliance with consensus standards. Even the consensus standards are under attack by extortion funding of Standards Australia. All this bully boy behaviour with a likely outcome of nothing. Whats the point of all this. Its time for the DOHA to swallow its pride and pull the pin. All of us will pay (more than we already have) one way or another otherwise.

Anonymous said...

Monday, August 15, 2011 9:35:00 AM simply does not understand. The government's thinking (ie Medicare Australia & DOHA) has not changed one iota in over a decade. They have wriggled, squirmed and twisted hundreds of times but one thing has remained constant - no-one can or will be permitted to control any national health database or major health repository except government. Major vendors will be contracted to provide 'a service' but NEHTA, DOHA and MEDICARE will have absolute control - that is their aim, always has been, always will be.

Anonymous said...

My interpretation of this, after reading it twice, is that the States have been well and truly snow-balled and hung out to dry.

From the evidence you have provided it seems that the states have never ever agreed to development of a PCEHR!!!! Can that be true???

If so they have been deftly corralled like a herd of wild brumbies into believing they have agreed to something they have not agreed to and are now bound to contribute funding to that end. Surely the States cannot have been that naïve or stupid.

Or have I got it wrong, or have you missed something?

Dr David More MB PhD FACHI said...

If anyone can find any reports of the States agreeing to the PCEHR I would love to see it. Their submissions (SA, Vic) certainly suggest they have been surprised that they expected to pay for something they did not agree to. Problem will be that I am not sure they can be forced...