It Seems I Am Not the Only One Concerned About the Current Planned Shape of the PCEHR.

The following appeared today.

Medicos wary of e-health draft concept of operations

• Karen Dearne
• From: The Australian
• June 07, 2011 12:00AM

PEAK information technology, medical and consumer groups have slammed the draft concept of operations for the $500 million personally controlled e-health record (PCEHR) and are demanding an urgent review before work continues.

"If substantial amounts of taxpayers' money are spent (on e-health) with little outcome, future funds will go to other programs," the Australasian College of Health Informatics has warned.

"Therefore, the PCEHR must work and must be sustainable."

The college says the draft does not "consider benefits in any depth nor how they may be practically achieved".

"It is to be hoped the Health Department will (undertake) a comprehensive cost-benefit analysis once the full scope of the PCEHR is determined," it says.

"This should be in conjunction with a review of the detailed planning, including functional and technical specifications."

The college notes that "substantial and critical pieces of work" should be completed before the Gillard government could realistically decide "not only whether to proceed with the PCEHR but whether it is prudent to consider other options", as the costs, complexity and risks likely outweighed any benefits.

The Australian Medical Association has warned that the concept is so flawed, doctors will not use the system. "Many of the problems are due to the decision to make it opt-in," it said.

"Disproportionate emphasis has been given to the concerns of an extreme minority who wish to mask details of their health record. A much simpler design would have resulted from making it opt-out."

Allowing patients to set limits on which healthcare providers can access their records, or to hide certain information, "means doctors will not be able to rely on the clinical information in the records", it said.

The Australian Privacy Foundation said the "lack of a coherent governance framework" lay at the heart of its concerns.

"The draft signals an even more confusing era of access by doctors, health organisations and many authorities than at present," it warned.

"But the governance framework for e-health nationally has not been devised.

"Work on an overarching structure, rather than the much-needed detailed plan, will occur late this year -- after the enabling legislation has been introduced to parliament.

"This draft seems to have been hastily conceived to meet the scheduled start date, rather than to inform people how the system will function in real life."

The Consumers Health Forum also "strongly argues that genuine, rigorous consultation on proposed governance models must occur" prior to the commencement date.

It noted that other contentious issues, such as possible data breaches, an efficient complaints mechanism and secondary use of personal data, had not been addressed.

More here:

http://www.theaustralian.com.au/australian-it/medicos-wary-of-e-health-draft-concept-of-operations/story-e6frgakx-1226070463633

With the range and depth of the comments and suggestions provided what is really important is the way NEHTA responds and re-does the ConOps to address the large range of serious issues raised.

As far as I am concerned we need a new Draft developed in interactive consultation with those who have submitted. The release of a new Draft should be followed by a reasonable period of discussion and review with a second submission round to ensure all the issues raised have been properly addressed.

It will be utterly crucial that the consultation process is seen to result in proper reasoned change to ensure there is no perception that the consultation has been a sham.

Were the various upcoming tenders to be awarded in the absence of finalisation of an essentially agreed ConOps and draft legislation that reflects these outcomes the likelihood of success of the overall program will be much reduced.

NEHTA needs to fully appreciate that unless the response to what is considered and fundamental criticism of the first released draft is satisfactory any claim it may have had to be a consultative organisation will be shredded.

David.