Sunday, July 20, 2014

Deloitte Have Been Engaged To Consult On Stakeholder Views On The PCEHR. Is This A ‘Claytons’ Consultation?

An e-mail came in from the Health Department a few days ago.
The gist of the e-mail is as follows.
“As previously advised, the Department will be undertaking a range of consultation activities to consider issues relating to the implementation of the Review recommendations. The Department has engaged Deloitte to support it in undertaking these consultations.
Consultation activities will include face-to-face meetings and a survey. Deloitte is currently finalising dates and venues for the meetings and will be writing to you directly to advise the details.
An online survey will also be made available to capture stakeholders' views.  This survey will be made available shortly and can be accessed until 1 September via  These details will be included in Deloitte's letter to you.  
The Department will also continue to receive any feedback on implementation issues until 1 September at
----- End Extract.
Deloitte have sent out a number of e-mails which suggest what the focus of the consultation is to be:
These include:
“It is very important that we talk to the right stakeholders to ensure that key issues are heard and understood, key ideas are incorporated and that the recommendations that arise from the consultation program are well informed. Therefore we would like to talk to members/staff of your organisation about the recommendations of the Review, with a particular emphasis on:
·         The adoption of an opt-out rather than opt-in model for consumer participation in the PCEHR – including information and education needs; security, privacy and usability issues and expectations
·         Records that should be included in the system
·         Record information access control and notification of access to the system.
The views expressed through the consultation process will contribute to advice to the Government on how best to implement the recommendations of the Review.”
And addressed to a different stakeholder:
“These discussions will have a particular emphasis on:
·         The adoption of an opt-out rather than opt-in model for consumer participation in the PCEHR – including information and education needs; security, privacy and usability issues and expectations.
·         The core clinical records that should be included in the system.
·         Record information access control and notification of access to the system.
·         How vendors work with Government to deliver PCEHR compliant software for clinicians
·         Recommendation 10 of the review – ‘Establish a regulatory body that monitors and ensures compliance against eHealth standards that are set and maintained by ACeH.’
The views expressed through the consultation process will contribute to advice to the Government on how best to implement the recommendations of the Review.”
I find all this rather worrying as it seems that what has gone on here is the Deloitte have been engaged to ask around stakeholders with a set of constraining assumptions regarding what should happen next.
I really want to see the really fundamental questions asked of stakeholders - e.g. who is the PCEHR for, what is it really for, can it be made to be seriously useful for clinicians and is what we have done so far actually fixable to deliver what is intended?
Unless we can be assured that whatever is being planned will deliver quality, safety and efficiency in the health system this may be an expensive waste of time and effort.
I have a strong feeling the questions above were not asked during the initial design phase and I fear the way the Department has set this consultation up the fundamentals won’t get properly reviewed and it will be assumed that the PCEHR is a good thing that basically needs to roll on!
One gets the sense that the Department wants all this wrapped up by September 1, 2014. If this is indeed the case then this may be what is usually described as a ‘Claytons’ consultation.
It does not look good to me!


Anonymous said...

It seems that the Department of Health now considers the PCEHR to be business as usual. They are proud of it; there is no rational measure of success, but that has never been an issue to the Department. No review that they fund will shut it down now. It has a life of its own. Deloitte and other consulting companies are also dependent on the ongoing review and enhancement of the PCEHR.
The last thing they want at this stage is anyone questioning the raison d'être of the PCEHR. It is a fait accompli.
Perhaps all we can do now is to try to ensure that there are improvements that make a difference?

Dr David More MB PhD FACHI said...

And what might they be? And how would they be better than just scrapping it?


Bernard Robertson-Dunn said...

In eHealth there seems to be an implicit assumption that, by gathering more and more data on a patient, better health decisions and outcomes can be achieved.

I have never seen this assumption validated and IMHO, it is false to the extent that the more useless information you have on a patient, the harder it will be for a health care professional to sort through it all, separating the good from the dross.

When it comes to personal health care, what I believe is necessary is relevant and current data, not more data. The relevance and quality of much health data deteriorates over time. There should be at least something in the eHealth strategy and in the PCEHR about addressing this issue.

The fact that there is nothing mentioned anywhere about data quality means that the real question about the PCEHR is not "has the PCEHR been implemented right?" but "is the PCEHR the right system?".

My answer to that question is conditional: Is the PCEHR intended to support decision making to achieve better health outcomes of individual patients? If this is true, then No, it will just make things worse and carers will drown in irrelevant data.

Is the real reason for the existence of the PCEHR to gather as much information as possible about as many Australians as possible? If this is true, then Maybe, but the government is being disingenuous and misleading and its not solving the right problem.

The push to opt-out strongly suggests the second reason.

The only saving grace is that a system intended for the second reason, but used for the first, cannot not succeed. Unfortunately, its failure will take a long time, cost a lot of money and put the adoption of effective and efficient health information systems back by decades.

Anonymous said...

It's Deloitte, not Deloittes.

Dr David More MB PhD FACHI said...

Fixed. Thanks.


Health software dev said...

Could you fix the links in the blog? The link to ehealth above is generated from your email app and doesnt resolve. And a lot of the time the links to articles (from the main page) take me to

Dr David More MB PhD FACHI said...

On the specific link - fixed. On the other links click the link NOT the title and they work..

That is why I always put the link above the title.

If anyone knows why Blogger adds the /null link to the title and how to stop it doing it - let me know!


Anonymous said...

I would be happy if they recommend that the specification and guidance provided by NEHTA is maintained appropriately, if we have to deal with these specifications with issues going back several years, confusing FAQ's, usability recommendations and not to mention the conformance requirements that seem to be created separately, I think I might give up and move to another industry. Honestly is NEHTA trying to be clever with this approach? I hope not because it makes it look like the nation is being run by a high school computer club, please replace whoever is responsible, they are hopeless and please! no more supporting information documents it's a mess

Anonymous said...

Anonymous July 21, 2014 9:08 PM

I would have to agree wholeheartedly, having these issues fixed and CCA brought under control would make life a lot easier. David maybe you could run a pole on this, it would be interesting to see others experience in the field.

I would like it noted this is not a reflection on those in NEHTA who tirelessly work to support us in understanding what these hacks all mean

Anonymous said...

July 20, 2014 7:41 PM nails it perfectly. They can't shut it down. If it were a submarine it could be left to rust on the bottom. It has assumed the proportions of a National Disgrace.

By comparison it's so much easier to cut the pararoos funding grant from $175,000 to $NIL.

Anonymous said...

Today’s report in PulseIT once again shines a spotlight on the PCEHR schmozzle.

--- DoH aims for pathology and imaging on PCEHR by December - Kate McDonald 21 July 2014.

The story reeks of haphazard confusion reflecting another desperate attempt by NEHTA and the Department of Health to make one believe there is progress afoot. Instead what we have is a series of admissions reinforcing the concerns of so very many experts that the PCEHR is an exorbitantly expensive dead goose.

Today we learn that:
1. January opt-out deadline is not possible

2. Authority To Post (ATP) is an interim step and not viable in the long term

3. ATP has not been developed because it is still being worked out!!! (spare me please)

4. Standard terms and measures required for the Pathology PITS and PITUS projects require much more work before atomic data can be added to the PCEHR.

With this sort of drivel there is no chance of sanity prevailing under the current regime.

Anonymous said...

There's nothing like thinking things through, and unfortunately there's been not much thinking things through with the PCEHR - or the review.

K said...

Everything must be done in a hurry. This is, presumably, to ensure that things are done well in service of the tax payer.

Anonymous said...

Deloitte did a great job on the National eHealth Strategy only to have their good work subverted and relegated to the scrap heap by Departmental bureaucrats.

The same will inevitably happen again. Although this time around the Department's focus will be on preserving the PCEHR irrespective of whatever Deloitte has to say on the subject.

Bear in mind, the PCEHR appeared as a thought bubble when Kevin Rudd's Health and Hospitals Commission submitted its draft report which overlooked any reference to the significance of eHealth in underpinning health reforms. Subsequently, as an afterthought and in response to extensive criticism from the health software industry, the Commission added some brief references to eHealth. In the process the Commission conjured up some shallow ill conceived blue sky thinking about a PCEHR which then took on a life of its own.

If Deloitte return to the original National eHealth Strategy well and good, although the problem in doing so is that they will be influenced by prevailing politics to wrap the PCEHR around a revised National eHealth Strategy. If Deloitte allows that to happen nothing of benefit will follow.

Anonymous said...

There is hope…
Jump forward in time…ten years have passed and the PCEHR is still there, hardly being used, recurrently funded each year by taxpayers.
A new eHealth strategy will be developed, and one of the recommendations will be to wind down the old PCEHR, the decommissioning of which will need time, resources, lawyers and IT gurus. What will we do with the data, how will we end the contracts, make staff redundant etc.
That’s how long it will take to undo. In the meantime, we are stuck with it, and it is needy.