Wednesday, February 29, 2012

NEHTA Is Now Failing In Its Core Task. They Are Withdrawing Issue Ridden Specifications After Announcing Them As Final Ages Ago!

In December 2010 NEHTA released its final specification for Electronic Transfer of Prescriptions Version 1.1
This specification was to be run through the Standards Australia IT-14 Committee to be endorsed as an Australian Standard.
Essentially this has failed to happen and NEHTA has now (14 months later)  produced a short 5 page update: Here is the key part of the first page:

Release Notification

Status Update

Electronic Transfer of Prescription 1.1

Final
Release Update: 27 February 2012 (Red is as document is presented showing how important it is I guess)
NEHTA published the Electronic Transfer of Prescriptions (ETP) 1.1 Specification Release in December 2010. This specification was progressed as a candidate for the Standards Australia IT-014 Informatics Community process with a view to realising a series of connected, formal Australian Technical Specifications. NEHTA is committed to supporting this standards publication process, and notes that a number of changes to the specification have been collected from relevant industry, policy makers and service providers, and have been applied to the specification.
NEHTA advises interested parties that ETP Release 1.1 will be superseded by an incremented release in mid-2012 and ETP Release 1.1 is now for information purposes only.
This Release Notification Status Update provides a broader communication as to the status of this Specification. Interested parties should contact NEHTA through the contact details at the end of this document should they wish to develop solutions based on ETP specifications.
-----
On page 4 (of 5) we find the following:

Known Issues

NEHTA has identified the following open issues affecting the release:
  • These specifications will be updated based on feedback through Standards Australia and are considered “for information only”. A future release expected in Mid 2012 will incorporate the this feedback.
  • The documents numbered 10 to 13 in the above list are platform-specific technical documents and have not yet been validated through live implementations in commercial clinical systems. For this reason the documents are identified as “Draft for trial implementation”. NEHTA will work with early implementers to offer support and contribute to validation of these technical documents.
  • The release specifies the National Authentication System for Health (NASH) as the mechanism for the provision and management of Public Key Infrastructure (PKI) certificates for mutual authentication and also message encryption and signing. At the time of the release, NASH is still in development, but is scheduled to be available to early implementers.
  • The release does not specify the technical mechanisms for document authors to digitally sign Clinical Document Architecture (CDA) documents. NEHTA is closely monitoring current national and international standards efforts to reach consensus on a CDA signing approach. NEHTA will work with Standards Australia and early implementers to finalise this mechanism.
  • The release does not specify the credentials used by document authors to digitally sign ETP documents. NEHTA continues to work with clinical stakeholders to reach agreement on and obtain Commonwealth, state and territory approvals of the credentials required for the digital signing of ETP documents. It is expected that the approved credentials will be based upon individual Public Key Infrastructure (PKI) certificates managed by the NASH.
  • The release does not specify the technical mechanisms for the submission of electronic prescriptions to Medicare Australia for PBS claim verification and audit, nor the technical mechanism for healthcare recipients to digitally sign for the receipt of PBS medications. NEHTA continues to work with Medicare Australia to specify these mechanisms.

Feedback

NEHTA continues to welcome feedback on the ETP package, which can be emailed to  medication.management@nehta.gov.au as can any questions relating to this package. Priority areas for feedback include errors of omission or commission, and issues that would adversely impact consumer choice and the timely provision of prescription and/or dispensed medication information.

Specification Development and Implementation

With the release of this final package, NEHTA’s ETP-related stakeholder engagement will turn to the development of guidance for the implementation and use of the ETP solution along with compliance, conformance and governance. NEHTA will also be actively seeking implementation partnerships.
The next release of ETP is expected mid-2012 and is being developed in concert with Standards Australia (IT 14-06-04 Working Group).
---- End Extracts
The full document can be found here:
What an amazing farce we have here. NEHTA and DoHA have known for ages that this specification was not fit for use and from other sources I have heard much of the concern and angst in the SA Committees about this and the associated pressure for delivery.
Who knows just why the Version 1.1 was left out there as final for so long. I guess they were busily working behind the scenes to get it fixed and just now realised they should say something. Another theory goes there was a DoHA payment due and NEHTA needed a deliverable. Don't you love conspiracy theories - I have heard this one from a few sources however.
Of course we also do have a HL7 V2 spec which is pretty widely used and which is probably also being updated. It is simpler and probably much more useable.
The MSIA have also known for a while the new NEHTA specs were not fit for use and mentioned that in one of their submissions.
I just hope no one has spent any money trying to implement the new one. Clearly NEHTA needs to utterly revamp the way it goes about the delivery of specifications such as this to ensure this sort of nonsense is not repeated. Essentially this is another 14 months wasted in a major and important application area.
David.

17 comments:

Anonymous said...

…….. early implementers … is mentioned three times. I find that very very interesting indeed.

The most important question arising from the following Three statements that must be answered unambiguously and immediately if the statements are to have any credibility whatsoever is:
EXACTLY WHO ARE THESE EARLY IMPLEMENTERS?

1. The documents numbered 10 to 13 in the above list are platform-specific technical documents and have not yet been validated through live implementations in commercial clinical systems. …………. NEHTA will work with early implementers to offer support and contribute to validation of these technical documents.

2. National Authentication System for Health (NASH) ………. NASH is still in development, but is scheduled to be available to early implementers.

3. Clinical Document Architecture (CDA) documents ……… NEHTA will work with Standards Australia and early implementers to finalise this mechanism.

Anonymous said...

I wondered that myself. They are obviously referring to early implementers for the Electronic Transfer of Prescriptions.

But surely that is not the Wave 1 or Wave 2 sites unless they have had their project scope and focus changed all of a sudden.

Perhaps these early implementers have yet to be identified. That leads one to ask are these early implementers Software Vendors or Medicare Locals or Community Pharmacies or what? Does anyone know?

Anonymous said...

Perhaps the Victorian Coroner's Recommendations on 15 February has focussed their attention on ETP.

* 518109 James (PDF 1.05MB)

http://www.coronerscourt.vic.gov.au/home/case+findings/coroners2+-+findings+-+inquest+into+the+death+of+james

Anonymous said...

reading the document from NEHTA, it basically states that as the documents are entering into Standards Australia's ownership the original NEHTA documents should not be considered current.

Seems fair enough to me, not sure why you would have an issue with this?

Dr David More MB PhD FACHI said...

Having declared the spec. Final 14 months ago - suddenly it is back in draft again essentially and may be sorted by mid year with luck. Maybe they could have noticed a bit earlier that it was not OK?

ETP has been underway since version 1.0 since a release (30/10/2009) and has been a NEHTA deliverable essentially from its inception.

My problem is that this is all taking years and somehow never seems to get done while we have a a working HL7V2 spec that works and needs some minor upgrade to be used while we get our act together - which seems to be taking decades.

David.

Anonymous said...

Where does it say on the ETP specs that they are final? I just downloaded a random one from here: http://www.nehta.gov.au/e-communications-in-practice/emedication-management and it says the following on the title page: e-Prescription CDA Implementation Guide
Version 2.1 — 17 Dec 2010 Draft for Trial Implementation (my emphasis).

Maybe I'm looking in the wrong place?

But to me "Draft for Trial Implementation" pretty clearly states the purpose of this document.

Anonymous said...

Ah, I see now - I've downloaded a few more of the documents. Some are marked "Final". But they are things like the requirements documents and the Structured Document Template (essentially a logical data model). The CDA Implementation Guide, which is what is to be implemented, was clearly marked as "Draft for Trial Implementation".

So, clearly the whole suite of documents were not final.

Obviously NEHTA screwed up with the "Final" label.

But any implementer would have known immediately that the spec he/she was coding to was certainly not final.

Dr David More MB PhD FACHI said...

Here is the heading of the Summary of the Whole Release 14 months ago.

Executive Summary
Electronic Transfer of Prescription 1.1
Final


As per the main document.

David

Dr David More MB PhD FACHI said...

The Exec Summary said the release was final. You are right they messed up!

So why 14 months till this was corrected?

David.

Anonymous said...

If the fact that NEHTA labelled a set of documents "Final" when some of them weren't (and were clearly labelled as draft) is the whole story here are we not making mountains out of molehills?

I would suspect that the reason it wasn't fixed was that no one noticed it and brought it to their attention.

Did you?

As an implementer I'd pretty much only look at the CDA IG and maybe the information model. So I might notice that the model was Final and the IG was Draft. Which is reasonable.

Dr David More MB PhD FACHI said...

Take it from me many in MSIA and IT-14 noticed and have expressed concern for months and months.

I doubt you have actually attempted to implement any of this - as others have - and found the problems.

This should have all been sorted ages ago.

The FINAL is just a symptom of a deeper malaise according to those I chat with.

The overall delay just reeks incompetence and is really pathetic given how important ETP is.

David.

Anonymous said...

I was under the impression that IT-014 has had ownership of these specs for close to a year now?

"Take it from me many in MSIA and IT-14 noticed and have expressed concern for months and months."
"Expressing concern" is somewhat different to ringing up, say, a helpdesk, and logging an error in a spec.

”I doubt you have actually attempted to implement any of this - as others have - and found the problems.”
You say that others have attempted to implement and have found the problems. (Of course, this is what “Draft for Trial Implementation” means – it’s a Draft – please implement as a trial and report any problems you come across) in your comment above.

Yet in the text of your post you say this:
“I just hope no one has spent any money trying to implement the new one.”

So which is it? You know these “others” that have tried to implement the ETP specs or you hope that no one has tried to implement the ETP specs? We are talking about the ETP specs here, correct?

And please don’t assume I haven’t implemented “any of this”.

”This should have all been sorted ages ago.”
What should have been sorted? There are mixed messages all over the place. NEHTA is rushing too quickly to get things done. NEHTA isn’t going fast enough – everything should have been sorted by now. MSIA thinks CDA + PDF will be great. No structured data allowed – structured data bad. Use V2.

I’m certainly no fan of NEHTA, but it really seems like NEHTA bashing if the worst thing you can find to complain about is a mis-labelled spec. I'm not sure how it "points to a deeper malaise" either.

I’m going to point out again – the Implementation Guide clearly states that it is a “Draft for Trial Implementation”.

Dr David More MB PhD FACHI said...

Look,

The spec has gone from being FINAL to being open to review after 14 months.

I know what has gone on behind the scenes and many in IT-14 and the MSIA see this spec as symptomatic of systemic failure.

Having talked to them I agree.

If you think it is all fine - go spend the money and implement a dud spec that it has taken 14 months to be acknowledged as such when it has been clear for months this was the case.

My point was and is that the faults have been know about for ages - the spec was unusable - and all the expert committee knew that.

It is not nitpicking - it is called demanding accountability from an out of control and sadly dysfunctional organisation.

End of conversation. And if you think I am concerned about the way NEHTA behaves - you are dead right.

David.

Anonymous said...

Being critical of the Nehta specs is not welcomed in any way, they want IT-14-xx to rubber stamp their proposals and simply reject critical comments.

Creating standard straight from the white board of an ivory tower architect is the worst possible way to create a standard. Standards should be created from working examples, that have been validated by real use. The CDA prescribing is a pale imitation of the V2 specs which actually cover a wide range of use cases. Its a misuse of CDA in fact, but if you try and say that they will try and bring you down quick smart.

This is simply the wrong way to do standards and the wrong way to get working eHealth. Nehta are smug and nasty, and often clueless!!!

Andrew Patterson said...

Surely the problem that the ETP spec has run into is that

a) not the same as the implementation of either of the two existing vendors (i.e. requires them to do work)
b) perhaps conflicts with the business models of the two existing vendors (i.e no reason for them to do the work)
c) is not HL7v2 and some people fervently believe that it should be

So of course none of those flaws (?) can be fixed just by putting it through a standards committee. If the expert committee don't like the underlying premise then you can't just fix some XML here, and update some service definitions there - they don't like the spec and don't want it to be the standard.

So to be charitable to NEHTA - they released a "final/draft for trial" spec - they tried to get it rubber stamped through Standards Australia (for more than a year) - met a lot of resistance and have now blinked and withdrawn it. But that is all kind of political, and is different from it having massive "technical" issues that were undiagnosed for 14 months.
(if there are actual technical issues can we have a discussion about those in a more precise "here are the issues", rather than a "my mates friend mentioned something was broken")

(btw can we also let go the notion we have a "working" v2 spec - we have a v2 spec that is probably implemented in some hospitals but we certainly don't have a widespread use of v2 for 'community' prescribing i.e. between completely separate organisations. So its not like all we have to do is "bless" the v2 standard and suddenly everything would be good to go)

Dr David More MB PhD FACHI said...

"So to be charitable to NEHTA - they released a "final/draft for trial" spec - they tried to get it rubber stamped through Standards Australia (for more than a year) - met a lot of resistance and have now blinked and withdrawn it. But that is all kind of political, and is different from it having massive "technical" issues that were undiagnosed for 14 months."

Andrew, not wanting to stir things up but don't you think it is possible that the objections might be a bit more serious than just politics. I really struggle to grasp how politics can be involved in the review of a technically sound ETP Standard.

My conclusion is that the Committee felt it was not technically sound or implementable rather than rejecting it our of political pique.

David.

Andrew Patterson said...

Well, I read the spec when it first came out, and even spent a few days implementing the server side interface (the store/fetch of script docs). It didn't seem "unimplementable", though I certainly only did a very cursory implementation.

I mean, all it does is encrypt a document, store it on a server, and let someone fetch it later. It isn't really rocket science - which is why I presume if problems can't be resolved in 14 month they are much more than basic technical issues.

(which is not to say that doing an implementation would not be HARD - i.e. needing to support AMT,
some tricky crypto etc. I'm sure it would cost vendors a fortune to implement. But I put that all again in the political category i.e. no reasons to spend the money/time - not fundamental technical flaws)