Friday, April 15, 2016
Submission Sent Yesterday To Department Of Health On Digital Health Strategy
Response To Draft Digital Health Strategy - Dr David More - April 2016
Having been sent multiple copies (presumably due to my voluntary unpaid role as the owner and operator of the Australian Health IT blog (http://aushealthit.blogspot.com) from diverse sources I have had the opportunity to review this document:
eHealth Working Group (EHWG)
A National Digital Health Strategy for Australia
July 2016 - June 2019
DRAFT 24 March 2016 Version 0.2
I believe my commentary should be of value to the EHWG and The Department Of Health as I am both a retired senior clinician as well as having decades of experience in Health Information Technology and Strategic Planning as well as having operated the above mentioned blog for over a decade.
The blog’s comment capability (both anonymous and identified) permits a valuable assessment of the views of the e-Health Community and provides very acute feedback when I make comments which are not seen as being correct.
The blog also has a poll capability.
The present poll allows an overall assessment of the draft Strategy to be offered by blog readers: As of late Wednesday (after just four days) the following results are seen:
How Do You Rate The Recently Circulated Draft National Digital Health Strategy?
Excellent 9% (11)
Good 8% (10)
Neutral 2% (3)
Poor 43% (56)
Just Awful 37% (48)
I Have No Idea 1% (1)
Total votes: 129
It is clear the blog community’s assessment is quiet negative.
I have created two blog posts which cover most of my views on the draft document and highlights the areas which need to be addressed:
First there was:
This e-mail and an attachment were sent out on April,4, 2016.
Attached is a copy of the draft National Digital Health Strategy 2016-2019 (the Strategy) for your review and comment. This Strategy has been developed in order to replace the previous 2008 National eHealth Strategy. The Strategy, once fully developed will be presented to the Australian Health Ministers Advisory Committee (AHMAC) before being recommended to the COAG Health Council for endorsement. This version is an early draft which not yet been considered officially, and as such does not currently have any formal status. We also appreciate that there is still work to be undertaken on the presentation of the document. What is important, at this stage, is to gain your feedback in relation to the content of this document. We are sending you this draft as part of a closed consultation process, and ask that you limit distribution and discussions on it to a representative group of your members at this stage.
The Strategy aims to recognise the need for increased collaboration across governments, healthcare providers, healthcare consumers, the private sector and software vendors to deliver an integrated digital health eco-system that supports healthcare provision within Australia. While it articulates the government programmes to be delivered, it's intended to provide certainty for private sector technology and innovators to encourage and foster innovation by the non-government sector. It acknowledges the need for real, consistent and ongoing engagement with consumers and healthcare providers in the design of digital health solutions.
The Strategy acknowledges the health system is changing rapidly, with new models of healthcare being regularly developed in response to opportunities, challenges and demands on the health system. Many of these changes are being driven by improved use of data. Technology is also rapidly evolving, and consumer and healthcare provider expectations of digital health solutions are increasing as they are exposed to advanced innovative solutions in other sectors such as retail and banking.
We will update the Strategy based on the comments that we receive from you and others during the consultation period. Once the Strategy has been endorsed, the Australian Digital Health Agency will take responsibility for the ongoing development, coordination and implementation of the Strategy through the National Digital Health Work Programme.
Any questions, comments or feedback that you have on the Strategy should be forwarded to James Robertson at James.Robertson3@health.gov.au by 14 April 2016.
Deputy Secretary and Special Adviser
Strategic Health Systems and Information Management
----- End Extract.
As you might expect I have had a number of copies forwarded to me as I was not on the original distribution list. (the full distribution list was provided to all recipients in what seems to be a minor security leak).
I have read the document through and have contributed my thoughts to one of the groups who were asked to respond. Sadly I can’t reproduce the document on the blog but I have made it available here for download:
I am making this file available to readers as I see them as part of a special group who have a major interest in the future of Digital Health and who need to have a say.
My thoughts are in 2 parts. My general response is that the present document has a very long way to go before it could be considered even vaguely satisfactory.
As far as specifics are concerned I would make the following points (in no particular order):
First I believe there are so many gaps in the work I believe the document is not really worthy of being described as a strategy - it is more just a really unconnected series of assertions and desires.
Second the document lacks any real insight into the current Health IT situation in Australia, especially it largely ignores the wide range of successful private sector initiatives.
Third, there is no clarity provided as to just who the intended audience for the strategy is and just who are to be assisted and supported by the plan. Is it for clinicians, consumers, the jurisdictions the Department of Health, the private sector or a mix/combination of all of the above or something else?
Fourth, as previously noted in this blog almost decade ago, a strategy without a funding plan and commitment is the emptiest of strategies / plans.
Fifth there does not appear to be anything that could be described as an implementation plan.
Sixth the current document totally fails to review the 2008 National E-Health Strategy to draw lessons on just what matters in actually delivery of a Strategy and fails to analyse where the successes and failures lay and why.
Seventh it is clear that the present document has been inadequately consulted on with many stakeholders largely ignored and no real consultative processes conducted, with an overwhelming predominance of Government staffers.
Eighth the document is excessively focused on the myHR and while recognising it is not fit for purpose - suggests the need to press on while trying to fix it. If ever you saw a chicken and egg problem - this is it!
Ninth the current document fails to grasp that Health IT needs to clearly recognise at least two customers - of which the health care providers are the most important - for the strategy (the other is the public/consumer). It is not clear the same solution can work for both classes of stakeholders.
Tenth the document is really weak on evidence, benefits analysis, overseas research and a realistic technology assessment and future analysis.
Eleventh there really is not a clear strategic situation assessment and a future vision.
Last it is not clear just how this document relates to the nascent Digital Health Authority - which is meant to be a strategic organisation.
Overall this document has a very long way to go I believe before being a half useful contribution to the state of play.
I would ask that those who are interested download the document and comment - I am sure DoH will have someone having a browse of the comments!
There were 14 comments made which can be reviewed from this link:
There was a second post a few days later:
As part of the recently released draft Commonwealth Digital Health Strategy we read the following:
The national My Health Record system was launched on 1 July 2012, as the Personally Controlled Electronic Health Record (PCEHR). The My Health Record system is a secure online summary of an individual’s health information. The individual is able to control what goes into their My Health Record, and who is allowed to access it. An individual’s My Health Record allows an individual and their healthcare providers to view and share the individual’s health information to provide the best possible care.
In order for the My Health Record system to be successful the following need to be addressed in the next three years:
· A critical mass of consumers registered;
· Active participation by healthcare providers, to both contribute clinical content and to use the information to inform clinical care;
· Sufficient clinical information available to make accessing the content worthwhile;
· Clinical information included of sufficient quality for healthcare providers to be able to confidently use the information for clinical care; and
· The use of the My Health Record needs to be embedded within the clinical practice and workflow of healthcare providers.
Strategies to address these goals have been reflected within strategic initiatives throughout this document.
Following a recent architectural review of the My Health Record system, it has been recognised that changes are needed to the design of the underlying My Health Record system technical infrastructure in order to meet emerging and future clinical requirements. These changes will be considered within this current planning period.
----- End Extract. (p39)
At the end of the same section we also read:
National Strategic Initiatives
S8.1 Design and implement changes to the My Health Record system technical infrastructure in order to meet emerging and future consumer and clinical requirements.
8.2 Develop and make available a My Health Record system release and development roadmap.
S8.3 Implement changes to the authentication services for connectivity to digital health solutions, focusing on improving registration and renewal processes for healthcare providers and organisations and to rationalise the number of authentication certificates required.
S8.4 Establish better alignment of the roadmaps for the National Health Services Directory, including the National Endpoint Proxy Service, with the other strategic initiatives detailed within this strategy.
All this is just amazing. What we have is the Government out there compelling a million or so citizens to be allocated a myHR, while admitting, explicitly, the present myHR product is simply not up to scratch.
Just what rationale can there be for not undertaking the re-design and re-implementation work - as well as, of course, addressing all the known issues (security, privacy, access controls, usability etc.) -before conducting the ‘opt-out trials’?
How on earth can the impact of opt-out be evaluated when the present mess is being trialled rather than a system that might actually be useful and clinically acceptable - assuming that the present myHR is reparable - which I very much doubt. No matter what is going on - the trials should not proceed until the myHR is shown to be fixable and then fixed and tested!
Seems someone is very keen to spend our money in a heck of a hurry for no good reason!
It is worth noting that points S8.3 and 4 highlight there is still a lot more work needed in the basic e-Health infrastructure as well.
Note: For more information or to download the draft plan go here:
Dr David More MB PhD FACHI
Here is the link to the blog and comments:
All of the above reflects my own views but in discussions with various Colleges and Professional Associations I have found an amazing level of agreement with concern and frustration with what has been offered within this document.
Clearly the document, as it stands, is simply not fit for purpose and needs a great deal more work to address all the issues I, and others, have raised.
The failure to produce a dramatically improved version of a National Digital Health Strategy will confirm the widely held view that the Department simply both does not listen and does not know what it is doing.
I would be more than happy to discuss and review future drafts.
Dr David More MB, BS, BSc, PhD, FANZCA, FCICM, FACHI.
14 April, 2016
Posted by Dr David More MB PhD FACHI at Friday, April 15, 2016