Sunday, February 19, 2012

I Think It Is Time To Say What The Senate Enquiry Into The PCEHR Legislation Needs To Answer. My Questions Still Seem To Be Current.

In my submission to the Senate Enquiry into the PCEHR Legislation and related matters I asked that the Committee address six questions to come to grips with what should happen next with the Bills, the PCEHR and the future of e-Health in general.
Here is what I said:
“The perspective I am adopting in preparing this submission is that of a clinician who has been actively involved in ‘e-Health’ for over two decades. It seems to me that it is important to step back from the Bills and ask the following.
1. Is the proposal for the PCEHR the ideal approach for Australia to be adopting in seeking to move the Health Reform Agenda forward - and if not what might be a better approach?
2. Is the PCEHR proposal an evidence based intervention that has a significant chance of actually improving healthcare outcomes in Australia?
3. Are DoHA and NEHTA ideally led and governed to succeed with such a complex and sensitive initiative and has DoHA, NEHTA and the Government really assessed the risks associated with the PCEHR proposal?
4. Has a Business Case / Cost Value Analysis specifically of the PCEHR proposal been undertaken (rather than generic analyses of ‘e-health’ benefits) and what were the findings from this work to support the present PCEHR plans?
5. What has been put in place to ensure that clinical practitioners will actually use the proposed PCEHR and ensure what is presently planned is successful?
6. Have DoHA and NEHTA taken on-board the very useful US Institute of Medicine Report entitled "Health IT and Patient Safety: Building Safer Systems for Better Careand ensured the issues raised - and especially the risks of harm to patient care and safety – have been fully addressed?
I would argue strongly that the answer to all six questions is a resounding no and the rest of my submission will develop the arguments to support this view.
I am firmly of the view that without radical re-design and re-scoping, the PCEHR Program will be seen by history as a profoundly flawed initiative which was badly executed and continuing a sorry line of similar initiatives as recounted in the Parliamentary Library report mentioned above.”
Before going any further I need to point out the Senate Web Site has been revamped and all the links have changed. Here is the current link to the enquiry page:
And here are all the submissions and two documents tabled at the Enquiry.
Well, after he hearing and the questions that were placed on notice it seems to me the topics I raised of patient safety and National e-Health governance are still right up there and really need to be properly addressed.
Of recent time we have seen the incentive issue re-emerge (at Senate Estimates and in the press) so I would now argue that the unaddressed elephant in the room is the evidence base and business case supporting moving on and continuing to fund the PCEHR. From Senate Estimates we see some funding is intended - but the quantum allocated will be a strong signal - in my view regarding the level of commitment. Less than $200Million per year will start to maybe signal a change of direction.
Given that there are essentially no funds presently in the Forward Estimates I wonder might it be that there is a plan to merge DoHA E-Health and NEHTA into a new government entity / unit as some wags are rumouring. There would be some sense in a move of that sort. Of course the risk of FOI requests against the old NEHTA might act as a bit of a constraint!
As far as an outcome of the enquiry is concerned it might be that we see acceptance of a continuing status quo or some minor tinkering around governance, consent and so on. Despite my personal hope for something more I fear we will see little more emerge - as much as I would like a clearer and more action orientated outcome. It might just be that the momentum towards the inevitable ‘train wreck’ cannot be overcome.
I certainly hope not!
I really do see this as a bit of a test of our system of Government. If we do not see a robust and well-crafted response to submissions and hearing I will suspect even more strongly we have a serious problem!

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