Sunday, February 06, 2011

The PCEHR Seems To Be Something that Needs A Lot More Than 16 Months To Deliver!

In case you were wondering what a the PCEHR System NEHTA has in mind is conceived to be I provide a brief extract from the late November, 2010 Concept of Operations.

On page 50 (as numbered) we read:

5.7 PCEHR-conformant repositories

The PCEHR system will consist of a range of PCEHR-conformant repositories operated at the national and regional level by a mix of public and private organisations. The PCEHR system capability will transition over time to provide access to richer clinical data stored in a range of PCEHR-conformant repositories.

The PCEHR system will consist of:

• A nationally operated repository, designed to provide a distributed set of secure highly available repositories for PCEHR records on a national basis.

This PCEHR-conformant repository will be used to ensure that there is a minimum level of health information available nationally and to support the sharing of critical health information when there is no other suitable repository available locally. It is likely that the national repository will be used to store health summaries and discharge summaries.

• Other PCEHR-conformant repositories will be accessible over time. These

repositories will typically be multi-purpose repositories that may have been designed for other purposes and now include new features to allow it to become conformant with the PCEHR system. Potential candidates include, but are not limited to:

– state, territory and regionally operated SEHRs (e.g. NT SEHR, NSW SEHR);

– Medicare Australia operated repository (e.g. for ACIR and Organ Donor Information);

– privately operated diagnostic services (e.g. repositories operated for/by Pathology and Diagnostic imaging companies);

– other sources including Australian Childhood immunisation register (ACIR), Adverse Drug Event Reporting (ADRAC), implant registers, cancer registries, breast screen registries, etc; and

– commercially operated PHRs (although this is subject to further policy review).

----- End Extract.

From other sources we know there will be an record indexing service, access control services and a template service (whatever that actually is).

What is not clear to me are the following:

1. Where are the health summaries and discharge summaries going to be sourced from?

2. Who will be accountable - and presumably paid - for keeping them current even after they have been uploaded?

3. Who will be accountable for errors in the summaries?

4. How will other non-government entities be paid for their time and trouble to populate the proposed repositories?

5. Who will fund the update of all the affected systems?

6. Who will train and support all the new e-Health users?

7. What happens if your GP does not want to share his records with the Government?

8. More important has anyone actually thought about any of this?

I note the RACGP has come out with some suggestions on e-Health Summaries. This is found here:

GP e-health summary

The RACGP is working closely with the National e-Health Transition Authority (NEHTA) to further define the core elements of the GP health summary and its application in an electronic health record. This will provide clinicians with key health information when providing care. Health information obtained through an accurate and current health summary will ensure safe and high quality care is delivered through access to the e-health summary in an electronic health record. Software specifications need to be developed to ensure the design is technically robust. The RACGP has established a group of GPs to work with NEHTA to ensure that electronic health records are integral to the management of patient care and the treatment of patients across the health sector.

Related files

Fact sheet - Allergies and adverse reactions (PDF 191KB)

Fact sheet - Health risk factors (PDF 186KB)

Fact sheet - Immunisations (PDF 186KB)

Fact sheet - Medical history (PDF 186KB)

Fact sheet - Medicines list (PDF 186KB)

Fact sheet - Relevant family history (PDF 186KB)

Fact sheet - Social history (PDF 184KB)

These are worth a browse - if only to see just how much information is envisaged in being shared. and the possible risks of sharing any of this information with anyone without explicit patient consent - which does not actually seem to get a major mention.

The College Standards make it clear that clear consent, beyond just consent for treatment, is required for clinical information to be transferred to third parties:

See pages 12, 29 and 93 among others.

The document is found here:

This caution should have been included at the header of these summaries I reckon.

I wonder how this is actually going to managed and signified. In the UK this has been a major issue which is still not actually resolved as far as I know.

It is also clear the College sees some other issues:

GP Health Summaries - Clear Guidelines Needed To Ensure Consistency, Australia

04 Feb 2011

A need to clearly define the key elements of the GP health summary and its application in an electronic health record has prompted the Royal Australian College of General Practitioners (RACGP) to develop a set of seven factsheets to provide advice to general practice and their teams.

The 4th edition of the RACGP Standards for general practices requires that practices can demonstrate that at least 75 percent of their active patient health records contain a current health summary (criterion 1.7.2). To meet the requirements for a satisfactory summary, elements such as allergies and adverse reactions, current medicines list, current health problems, relevant past health history, health risk factors, immunisation, relevant family history and relevant social history need to be included. But what does 'current' or 'relevant' mean?

RACGP e-health spokesperson Dr Chris Mitchell said that there is a need to clearly define the core elements of the GP health summary as health information available through an accurate and current health summary will ensure safe and high quality care for patients.

----- End Extract.

There is a good way to go in sorting out content, accuracy, sharing and consent at the very least!

As for paying for all this some of the issues are flagged here!

If ever there was something that was not yet properly thought through, seems to not have absorbed lessons from overseas and needs a lot more consultation and work this PCEHR is it!

Time to swallow the pride and start really consulting! As the poll that will report tomorrow shows very few reckon this project - as presently conceived - is a goer of any sort.



Anonymous said...

There is nothing new in the RACGP Fact Sheets and as such they therefore do not contribute any new knowledge or provide any additional enlightenment / guidance to NEHTA than has been available for many years.

I see this as nothing more or less than a politically contrived positioning statement engineered by the RACGP and NEHTA to give credence to each other’s claims for more money for ehealth.

In one of his slides, Philip Davies, sums these shenanigans up by pointing to $1,076 million under the heading “PROMISES, PROMISES”.

Anonymous said...

Healthcare practitioners (professionals) have been sharing clinical information between third parties for as long as I can remember without any additional consent being required.

They have done so by telephone, by corridor conversations, by letter, by photocopying, in group clinical review meetings, at post mortem, etc.

The consent under which they have done this has been implied consent by virtue of the patient coming to us for treatment and by virtue of the patient having investigations undertaken which have been ordered by us and by virtue of the fact that the patient expects us to communicate with each other in the patient's best interest.

When however it comes to 'other' 3rd parties like lawyers, insurance companies or employers requesting information about the health status of an individual, more formal evidence of consent is required to be sighted by any health practitioner, doctor, dentist, physiotherapist or whoever, before information will be provided and only then will the astute practitioner provide a level of information as specified by the person whom it concerns.

It is that straightforward, always has been, always will be. In theory the advent of computers does not change anything; with the exception, that it is now so much easier to push a couple of buttons, cut and paste, and send. It is this aspect of computerization that is driving people to push for tighter levels of consent.

Perhaps it wouldn't be a problem if the patient had access to their PCEHR from which consent to send information to a third party (insurance company, lawyers, employers, etc) was made available by the patient without including holus-bolus the interchange of information between practicing health professionals working for and in the interest of the individual patient in the provision of health care to that individual.

Anonymous said...

$1,076 million is a lot of money. Even more so when over the years there has been no public accountability as to how, where and when this money has, is, or is going to be spent.

It is all hidden behind obfuscation, hyped up rhetoric by self opinionated noise merchants who label themselves as experts, and organisations like NEHTA who, as the Secretary of DOHA (Jane Halton) keeps reminding us at Senate Estimates, do not account to the Department because the Department has no control over NEHTA.

Is it any wonder those of us who have patients in dire straits, whose homes and everything they own has been washed away, who can see no future, who are at the end of their tether, contemplate in absolute bewilderment how many homes, families and lives could be rebuilt for $1,076 million - approximately 3,000 ++ homes.

Anonymous said...

$1076 million is alluded to on Philip Davies "promises, promises" slide. But this is not the total sum. For some reason, Davies does not include the earlier money allocated to NEHTA, which can be found cited, as an example, in the 2007 BCG Review of NEHTA (available at: )

which states:-
"NEHTA’s brief was to advance the Australian eHealth agenda — specifically through the development of standards, clinical terminologies and patient and provider identifiers — by mid-2009. To do this, it received an initial $23m in base funding in 2005, followed by $130m in COAG funding in February 2006. NEHTA’s brief was intentionally kept narrow to allow early gains on the foundation elements of eHealth for uptake by pending jurisdictional projects."