As reported a day or so ago the Senate is conducting a short enquiry into the Health Identifiers Bill. The deadline for response is very tight indeed.
Tight deadline for e-health identifier bill inquiry
- Karen Dearne
- From: Australian IT
- February 25, 2010
THE controversial Healthcare Identifiers Bill has been referred to a Senate inquiry, but interested parties will need to meet a very tight deadline for comment, with a report due back before federal parliament by March 15.
The Senate Scrutiny of Bills committee said the HI bill "seeks to introduce a significant change by implementing a national system to assign healthcare identifiers for consumers and providers".
Under the proposed law, introduced by federal Health Minister Nicola Roxon, unique identifiers will be mandatorily issued to all Australians by Medicare Australia, which will operate the HI regime.
If the bill is passed, from July 1 all Australians will be issued with a 16-digit unique number linked to existing Medicare numbers, while all medical providers and healthcare organisations will also be given a unique 16-digit identifier.
Unique identifiers provide a key foundation for more widespread information-sharing of patient records across the health sector, and are intended to ensure correct assignment of personal data in electronic health record systems, and secure exchange of communications between doctors.
But health consumer and privacy advocates have warned of the dangers of abuse or exposure of personal medical information, as well as the potential for government-issued numbers to morph into a broader national identity scheme.
The Senate Community Affairs committee will have to consider whether the bill contains sufficient privacy safeguards, the operation of the HI service, including access to identifiers, and its relationship to the wider national e-health agenda and future electronic health records.
Written submissions should be lodged by March 5, and public hearings are expected to be held in Canberra on March 9-10.
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The story was also picked up here
More input sought for e-health Bill
By Suzanne Tindal, ZDNet.com.au
26 February 2010 03:27 PM
Health Minister Nicola Roxon has referred the e-health Bill for the introduction of a universal identifying health number — the Healthcare Identifiers Bill — to a Senate Committee.
According to the minister's office, the Bill was introduced to the Senate Standing Committee on Community Affairs to satisfy "ongoing community and stakeholder interest".
"Whenever there are high levels of community interest in [a] bill it's very common practice for a bill to be referred to the committee," Roxon's spokesperson Katie Hall told ZDNet.com.au.
The committee is expected to look into privacy safeguards in the Bill, which involves the issue of a unique 16-digit unique number to Medicare members, medical providers and healthcare organisations. The committee will also look at the operation of the services required to utilise the numbers, and the Bill's expected role in the national e-health agenda.
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Here are the full details of the enquiry.
Healthcare Identifiers Bill 2010 and Healthcare Identifiers (Consequential Amendments) Bill 2010
Information about the Inquiry
On 24 February 2010 the Senate referred the Healthcare Identifiers Bill 2010; for inquiry and report.
The Healthcare Identifiers Bill 2010 establishes the national e-health Healthcare Identifiers Service to provide that patients, healthcare providers and provider organisations can be consistently identified.
The Healthcare Identifiers (Consequential Amendments) Bill 2010 (introduced with the Healthcare Identifiers Bill 2010) amends the Health Insurance Act 1973 to authorise the Chief Executive Officer of Medicare to delegate functions to support the Healthcare Identifiers Service (HIS); and Privacy Act 1988 to: provide that the HIS comes under the jurisdiction of the Privacy Commissioner; and make amendments consequential on the Personal Property Securities (Consequential Amendments) Act 2009.
The following issues were outlined for the Committee to consider during the inquiry:
• privacy safeguards in the Bill
• operation of the Healthcare Identifier Service, including access to the Identifier
• relationship to national e-health agenda and electronic health records.
Submissions should be received by 05 March 2010. The reporting date is 15 March 2010.
The Committee is seeking written submissions from interested individuals and organisations preferably in electronic form submitted online or sent by email to community.affairs.sen@aph.gov.au as an attached Adobe PDF or MS Word format document. The email must include full postal address and contact details.
Alternatively, written submissions may be sent to:
Department of the Senate
PO Box 6100
Parliament House
Canberra ACT 2600
Australia
Notes to help you prepare your submission are available from the website at http://www.aph.gov.au/senate/committee/wit_sub/index.htm. Alternatively, the Committee Secretariat will be able to help you with your inquiries and can be contacted on telephone +61 2 6277 3515 or facsimile +61 2 6277 5829 or by email to community.affairs.sen@aph.gov.au.
Inquiries from hearing and speech impaired people should be directed to Parliament House TTY number 02 6277 7799. Adobe also provides tools at http://access.adobe.com/ for the blind and visually impaired to access PDF documents. If you require any special arrangements to enable you to participate in the Committee's inquiry, please contact the Committee Secretariat.
Once the Committee accepts your submission, it becomes a confidential Committee document and is protected by Parliamentary Privilege. You must not release your submission without the Committee's permission. If you do, it will not be protected by Parliamentary Privilege. At some stage during the inquiry, the Committee normally makes submissions public and places them on its website. Please indicate if you want your submission to be kept confidential.
For further information, contact:
Department of the Senate
PO Box 6100
Parliament House
Canberra ACT 2600
Australia
Phone: +61 2 6277 3515
Fax: +61 2 6277 5829
Email: community.affairs.sen@aph.gov.au
This information is found here:
http://aph.gov.au/Senate/committee/clac_ctte/healthcare_identifier/info.htm
My Draft Submission is as follows and I would welcome comments and suggestions.
----- Begin Submission.
Submission to the Senate Standing Committee on Community Affairs.
Topic: Enquiry into the Healthcare Identifiers Bill 2010 and Healthcare Identifiers (Consequential Amendments) Bill 2010
Submission Author:
Dr David G More BSc, MB, BS, PhD, FFARACS, FCICM,FACHI.
Author’s Background. The author of this submission is an experienced specialist clinician who has been working in the field of e-Health for over 20 years.
General Points on the Bills.
First without seeing the associated regulations it is impossible for the Senate committee to know what we are actually going to wind up with as a final implemented system. As the Late US President Ronald Regan put it "Trust but Verify" The Senate should insist in seeing at least the proposed draft regulations.
Second the Bills are being treated in isolation from the larger e-Health agenda for which there is at present no effective leadership, organisation or governance as recommended in the 2008 National E- Health Strategy which was developed for the Australian Health Ministers Council (AHMC) by Deloittes and subsequently agreed. To be undertaking legislation and implementation with this gap not addressed is as Sir Humphrey would say ‘exceptionally courageous’.
Third to not be undertaking small and large scale pilot implementations before a nationwide rollout is, in my view just foolhardy and just nonsensical. No responsible organisation just switches on a national system of this scale without a lot of operational testing etc. The whole project poses massive risk from an organisation that has been found wanting in other much less complex implementations. (e.g. Medicare Easyclaims). Internationally and at a State level in Australia there have been very many difficulties with many such projects and very few obvious successes.
Fourth it would seem to be quite strange to be passing legislation for the HI Service without being clear what comes next. A COAG proposal is being developed by Department of Health Ageing for a fuller E-Health approach at the time of this submission but is still secret. The time for legislation is when that fuller agenda is public and has been debated by stakeholders.
Fifth there is no evidence there will be wide-spread use of the HI Service until there are some arrangements put in place to ensure they have their reasonable time and costs rebated in some form. I am informed NEHTA has approached their Board on this matter – but in absence of this approval the entire Health Identifier Service risks being an expensive white elephant
Last, while there is no doubt there would be major benefit from a smooth running efficient National Identifier System the costs of ongoing delivery and maintenance (recording births, deaths, address changes and so on for some 22 million souls) are not addressed and may be very considerable. Other options exist for addressing Health Identification but these have never been explored and there has never been a business case developed .
All the above points ignore the various risks to privacy and identity protection which I am sure others will provide detailed submissions upon.
In summary it is my professional opinion that the community is entitled to be presented with legislation that takes a far more holistic view of the way e-Health systems and services are to be delivered to Australians and addresses clearly and systematically all the possible risks that are associated with the implementation of large complex systems as well as providing an optimal framework for governance, leadership, privacy protection and engagement with the caring professions and consumers who are going to be required to use these systems.
The present proposed legislation is deeply inadequate and there are major implementation risks with the project overall which I do not believe have been treated frankly by the enthusiasts for this Bill in its present form.
Dr David G More.
----- End Submission
I would be keen to have comments that can improve this draft.
David.
Dom Nicastro, for HealthLeaders Media, February 12, 2010