Sunday, September 06, 2015

There Are A Lot Of Submissions On The PCEHR And IHI Legislation. I Wonder When We Will Get A Government Response?

This appeared a few days ago.

Electronic Health Records and Healthcare Identifiers: Legislation Consultation - Public Submissions

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On 28 May 2015 the Department of Health published a discussion paper (Word 154 KB) outlining proposed legislative changes to the Healthcare Identifiers Act 2010 and the Personally Controlled Electronic Health Records Act 2012. Submissions were invited from interested parties by 5pm Wednesday 24 June 2015.
Here is the link:
According to the site there are 137 submissions to date.
The last submission was received on 28 July 2014.
It is now early September so the Department have had a good month or so to digest what they have been told.
In the past I have noticed that there has been virtually no response to submissions made to the Department on matters like the PCEHR and the IHI.
To me the test for the Department is to now develop a document outlining what they have been told by all the submissions and what they propose to do to address the concerns that have been raised.
For them to not do so will confirm to pretty much everyone that responding to requests for Submissions is just a waste of time.
I look forward to the analysis of the Submissions and an explanation of what will be addressed flowing from the Submissions. In a reasonable world the Department's response would have been released with the Submissions - but that would be expecting too much I suspect!
I passing I would note - having read a range of the submissions - that as far as those who have responded there are a very large number of problems which need addressing that have been raised.
The ACHI submission - Number 110 - provides a very useful guide to many of the issues and is well worth a browse to get a flavour.
Many I browsed continue to be pretty sceptical of just how well the PCEHR can be made to work and what it will actually deliver - and some a pretty hostile to the idea of opt-out while others are keen on the idea. Pretty much all respondents see some difficult issues which will need to be addressed.

I guess, however, I am dreaming in hoping to see a worthwhile response.
David.

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