Tuesday, February 02, 2016

We Now Have The Law And Regulations For The Australian Digital Health Agency. Some Interesting Points.

This appeared late last week.

Public Governance, Performance and Accountability (Establishing the Australian Digital Health Agency) Rule 2016

- F2016L00070
Rules/Other as made
This rule establishes a corporate Commonwealth entity under section 87 of the Public Governance, Performance and Accountability Act 2013 to be named the Australian Digital Health Agency. Provides functions, governance arrangements, reporting requirements and transitional provisions to transfer assets and liabilities from the National E-Health Transition Authority Ltd.
Administered by: Finance
Made
28 Jan 2016
Registered
29 Jan 2016
Date of Ceasing
To be ceased 01 Apr 2026
Reason for Ceasing
Here is the link:
Most of the terms look to me to be pretty routine. What I was interested in was the input to the Board of Clinical and Technical advice. (There are also similar committees for Jurisdictional, Security and Privacy and Consumer issues.)
From the explanatory memorandum we read:
Item 45 Functions of Clinical and Technical Advisory Committee
This item outlines the functions of the Clinical and Technical Advisory Committee.
The functions of the Clinical and Technical Advisory Committee are:

·         providing advice on the efficient and effective delivery of clinical care through the use of digital health, which may include a range of digital health systems and solutions;

·         providing advice to the Board about the architectural integration of digital health systems (including the integration of digital health systems and solutions to ensure their interoperability);

·         making recommendations to the Board in relation to priorities for investment in, and development and implementation of, national digital health systems;

·         providing advice to the Board on changes (which may include improvements) to the design of digital health systems to improve the useability and usefulness of digital health systems for clinicians and health consumers; and

·         providing advice to the Board on proposed improvements to digital health systems to improve their usability for clinicians and users of the systems, including health consumers.
From the regulations we read the following:

Division 2—Clinical and Technical Advisory Committee

             (1)  The Clinical and Technical Advisory Committee consists of a Board member (other than the Board Chair) and up to 10 other members.
             (2)  The Board member must be:
                     (a)  a Board member with the skills, experience or knowledge mentioned in paragraph 19(3)(a); or
                     (b)  if there is no such Board member—a Board member nominated by the Board.
             (3)  A person is not eligible to be appointed as a member of the Clinical and Technical Advisory Committee unless the person is:
                     (a)  a medical practitioner with specialist registration; or
                     (b)  a registered pathologist; or
                     (c)  a medical practitioner with specialist registration in diagnostic imaging; or
                     (d)  a registered nurse practitioner; or
                     (e)  a registered nurse; or
                      (f)  a registered allied health practitioner; or
                     (g)  a registered pharmacist; or
                     (h)  a registered dental practitioner; or
                      (i)  a Chief Information Officer (however called) of a public hospital; or
                      (j)  a Chief Information Officer (however called) of a private hospital; or
                     (k)  a Chief Information Officer (however called) of a non‑health related entity; or
                      (l)  a Chief Medical Officer (however called) of a hospital; or
                    (m)  a Director of Nursing (however called) of a hospital; or
                     (n)  a Clinical Information Officer (however called) of a hospital; or
                     (o)  a person with experience in health industry software; or
                     (p)  a rural doctor; or
                     (q)  a member of the Consumer Advisory Committee with skills, experience or knowledge in consumer health advocacy; or
                      (r)  a Fellow of the Australian College of Health Informatics.
             (4)  The Chair of the Clinical and Technical Advisory Committee is the Board member mentioned in subsection (2).
             (5)  Subject to this section and any written directions of the Board, the Clinical and Technical Advisory Committee may determine its own procedures.
                  The Clinical and Technical Advisory Committee has the following functions:
                     (a)  to provide advice to the Board about the efficient and effective delivery of clinical care using digital health;
                     (b)  to provide advice to the Board about the architectural integration of digital health systems;
                     (c)  to make recommendations to the Board in relation to priorities for investment in, and development and implementation of, national digital health systems;
                     (d)  to provide advice to the Board on changes to digital health system design to improve clinical usability and usefulness based on experience with the use of digital health systems;
                     (e)  to provide advice to the Board on proposed innovations and measures to improve the efficiency and effectiveness of digital health systems for clinicians and users of the systems.
----- End Extract.
What I found interesting was that non-rural doctors who are not specialists seem not to be able to be members. I wonder does that exclude people from the AMA and RACGP who are not specialists?
It is also interesting that the Fellows of the Aust. College Of Health Informatics are eligible for membership but not HISA CHIA’s and senior HIMAA people etc. I wonder how that happened.
To me the biggest gap in all this is the lack of an overall catch all that would allow the committee to advise on all relevant e-Health matters. Would be good to see that included!
David.

9 comments:

Bernard Robertson-Dunn said...

This is interesting one:
(k) a Chief Information Officer (however called) of a non‑health related entity; or

So the CIO of any entity, such as the Reserve Bank or BHP or GlaxoSmithKline or ASIO could qualify.

Considering one of the responsibilities is "architectural integration of digital health systems", one might have expected that the list would include people with relevant experience. Being a people manager such as a CIO or "a person with experience in health industry software" just doesn't cover it.

It's almost as though they don't understand the sorts of skills required to develop innovative systems in an environment where such things have never been done successfully before.

Sad.

Anonymous said...

David,

A GP who has met the requirements of the RACGP is considered a medical practitioner with specialist registration.

http://www.medicalboard.gov.au/Registration/Types/Specialist-Registration/Medical-Specialties-and-Specialty-Fields.aspx

Dr David More MB PhD FACHI said...

Good - saves DoH some embarrassed with the criteria they have set...

Anonymous said...

Bernard NEHTA and DoH have gone for so long without Architecture disciplines I doubt they know what it is other than a set of flat technical documents and requirement in an old project plan. You just need to look at the rubbish they put out in the last four or five years to see evidence.

Anonymous said...

You just need to look at the rubbish they put out in the last four or five years to see evidence.

The rubbish you refer to was NEHTA's output under Peter Flemming and his band of merry men. I don't think it fair to lump DOHs Paul Madden into the same camp because the Department and other jurisdictions were very much under the spell of NEHTA, its Board and the Department's Secretary; none of whom would listen to anyone else. While Flemming was able to exercise power no matter how incompetently I suspect Madden was relatively powerless and dragged along more as a victim of the forces in play.

Anonymous said...

So no room on the board for patients, taxpayers, consumers, the actual 'IT end users'? So this looks like more elitist, more of the same to come...

Anonymous said...

February 03, 2016 2:16 AM if you feel so strongly about that you should make your concerns known to the independent chair Ms Kruk.

Bernard Robertson-Dunn said...

Re "... NEHTA and DoH have gone for so long without Architecture disciplines I doubt they know what it is other than a set of flat technical documents and requirement in an old project plan."

That's pretty obvious. Having reviewed all the publicly available documents and asked Health if there are any more (answer - no) the thing that is missing and which explains all the shortcomings of the system is any analysis of the information needed to make a health record system useful.

In technical terms there is no Information Architecture, containing, amongst other things, Entity Relationship Diagrams and Data Flow Diagrams. These are normally created in order to understand the information problem, to get end user agreement as to the system context and behaviour and goes a long way to defining the business requirements.

Without an Information Architecture you just don't know why you are building the system and how it's going to be used.

Sound familiar?

Anonymous said...

Re you should make your concerns known to the independent chair Ms Kruk.

I agree. It's no good complaining after the horse has bolted. And don't say it wouldn't make any difference because it might. They've got one hell of a problem and they need all the help they can get to find a way out of the mighty crevasse they have fallen into.