Thursday, June 09, 2011

NEHTA and DoHA Have a Big Job of Reading and Responding to the Submissions on the PCEHR ConOps.

The following few articles appeared in the last day or so.

First we have:

PCEHR deadline too tight, says MSIA

  • Karen Dearne
  • From: Australian IT
  • June 08, 2011 6:16PM

THE Medical Software Industry Association says the "extremely tight" July 2012 deadline for the start of the $500 million personally controlled e-health record program risks patient safety as there is little time to ensure new software is free of bugs.

The MSIA highlighted glaring holes in Labor's e-health proposal in its submission to a government consultation on the PCEHR.

"The timeline to develop, test and deploy software to support the PCEHR is extraordinarily short," it warns. "Many different changes are required in many different settings, and there will be safety issues unless great care is taken to ensure software is fit for clinical use."

"Key elements that are missing include the Australian Medicines Terminology (AMT), the Healthcare Identifiers service and the National Authentication Service for Health -- described in the draft concept of operations as ‘existing’ -- yet to date not one of these enablers is being used ‘live’ in any broad clinical setting," it said in its submission to the Health department on the draft concept of operations (ConOps) for the PCEHR.

"There is no timeline that tells us when these will be ready, and their availability is dependent on the (outcome) of work by the National E-Health Transition Authority and other third parties.

"But without documented delivery dates, it is impossible for software-makers to schedule their development, testing and implementation work."

NEHTA chief executive
Peter Fleming last week told a Senate estimates hearing that each of the PCEHR components was "tracking to its critical path".

At a separate session, Medicare’s deputy chief executive, health, Malisa Golightly, said the identifiers service "is operating. It is ticking along", confirming there were no particular problems.

But in February, the Health department
banned the use of the $90m HI service in any live environment due to concerns over the system’s safety.

Declared live by Health Minister Nicola Roxon last July, it has been sitting idle while software interface specifications and compliance issues are thrashed out.

The Australian understands some progress has been made, with a number of vendors signing to access Medicare’s HI testing environments, but licence conditions are still to be agreed.

The MSIA refers to this in its submission, saying: "There needs to be a clear indication of responsibilities, relationships and governance for all the agencies involved. This includes liability issues for information provided by government or its managing agent for the HI or the AMT, for example."

It is also seeking recognition of the need for a commercially sustainable model for software makers.

"There is no indication there will be any satisfactory agreement with current vendors to ensure that their systems will interoperate with the PCEHR in order to receive and send patient information in a safe and secure way," it said.

Lots more here:

Next we have:

GPs need funding for e-health data quality

By Suzanne Tindal, on June 8th, 2011

The Royal Australian College of General Practitioners (RACGP) has recommended that GPs be allocated more funding from Medicare to balance out extra time they will need to spend managing a patient's electronic health record.

The government hopes to have personally controlled electronic health records (PCEHR) up and running by mid next year. Different medical providers will contribute to the record, which will not be stored together, but use indices to link information.

The college warned in a submission to a Concept of Operations for the scheme that as the record will draw on data from multiple sources, contradictions or incorrect information could make its way into the record.

The college suggested that all professions that were able to contribute to a patient's consolidated view should have to undergo a "formal clinical safety assessment" conducted by an approved authority, such as the Australian Commission on Safety and Quality in Health Care.

However, the college also said it was important that a healthcare organisation ensured the accuracy of the information in the patient's e-health consolidated view and shared health summary, which should be carried out by the patient's nominated provider. It said that the GP was the "best-placed health professional to assume the role of nominated provider", and indeed believed that unless the patient said otherwise, their usual GP should be the default nominated provider.

The work required to complete this task "must not be underestimated", according to the college.

"IT is the RACGP's belief that the nominated healthcare provider will be burdened with substantial risk and considerable time spent on validating and updating the information in the Shared Health Summary," it said.

RACGP hoped the government would recognise the need for funding to GPs to manage the record, and not just to implement it, with funding required for training and education and a quality assurance process. In addition, the benefits of the record will flow to other health professionals more than to GPs, the college said.

"Accordingly, the RACGP would urge that government consider appropriate amendments to the Medicare Benefits Schedule to recognise the additional work general practitioners will undertake in consultations initiating and maintaining the patient's shared health summary and PCEHR," it said.

It believed that unless this occurred, there was a risk that providers would refuse to participate in the process.

The college also expressed concern about the complexity of access controls, saying that patients will require education to understand the controls, or they won't use them.

Again lots more here:

Third we have some Departmental comment:

PCEHR draft operations out in August

  • Karen Dearne
  • From: Australian IT
  • June 09, 2011 11:39AM

A REVAMPED version of the draft concept of operations for the $500 million personally controlled e-health record will be issued in August, after the federal Health department was swamped by late submissions.

A total 144 submissions have been received following an extension of the deadline by one week to June 7. Only 11 submissions had been received by the original deadline.

A Health spokeswoman told The Australian more than 40 per cent of the responses came from consumers.

"The National e-Health Transition Authority and the department will review the submissions, and all input will be considered as part of updating the ConOps, which will be released in August," she said.

"The department will also publish submissions (where consent has been provided) on the website, and ensure this information feeds into change management and benefits realisation work streams."

More here:

Increasingly the submissions are appearing on the web-sites of the organisations and a search for PCEHR and Submission will find a great deal of reading - limit the search to the last week or so and it works well!

Browsing through it seems most of the issues raised on the blog are raised by a few others - with all sorts of additional ideas coming forward as people assess the ConOps from their perspective and interests.

As I said a day or so ago - the test will be to see just how well this information is digested and turned into a proposal that might actually be useful and viable!



Anonymous said...

A lot of people have spent a lot of time responding to the PCEHR ConOps document not to mention the time and resources spent in the pre-document consultation sessions!.

My overall impression is that it is a document cobbled together by many people in great haste to meet some artificial politically imposed unrealistic deadlines established to create a sense of great urgency and that something of great note is underway.

The MSIA response in particular highlights a disconcertingly large number of major deficiencies and shortcomings of the ConOps document that it is perfectly clear the whole thing needs to go right back to square one for a total rethink.

I doubt all the proposals will be read and given the depth of thinking, reflection and comprehension they deserve, but they may be skimmed - to what end? Thank you for your response.

Anonymous said...

I was involved in those consultation sessions. Virtually without exception whenever those invited raised a point, a "Nehtian" (as they like to be called) said "We've thought of that" and gave a pretty extensive answer. Generally it was very complex. When challenged on the complexity they said often "It's for the vendors to work out" or "It's very simple really". I also remember one senior architect saying "It's never been done before anywhere in the world". I don't think it needs to be as complex as it appears to have become. I think a lot of the solutions are addressing problems that the majority of Australians don't think are problems, or they are so rare that for the very small number of people who might be affected it's not worth spending a large amount of money on. I've spoken with some of the people in my consultation team and we aren't sure the Concept of Operations is what we thought it would end up being. I guess that's the nature of consultation though.

Anonymous said...

From a psychologists perspective Friday, June 10, 2011 8:10:00 PM. describes a situation which others have often referred to on many occasions previously. I hesitate to go much further here suffice to say that if an Occupational Psychologist was let loose inside NEHTA you would find there is a cohort of individuals who fit a particular type of personality trait which has been present in NEHTA since its founding CEO was appointed and employed senior personnel in his own image.

".... and gave a pretty extensive answer. Generally it was very complex. When challenged on the complexity they said often "It's for the vendors to work out" or "It's very simple really". I also remember one senior architect saying "It's never been done before anywhere in the world".

The above quote is suggestive of a particular type of personality. 'Their' fulfillment is the 'confusion / disruption' - the more extensive - the better. That is their modus operandi and they are doing their job well - indeed they are doing their job to perfection. They are difficult to identify and even harder to remove.

Anonymous said...

Yes, it would appear the 'narcissistic' waters run very, very deep at NEHTA, and spring forth from the very top, and spread very thickly across the senior management ranks.

And not a conscious thought may be given that the "tax payers" are supporting their self-indulgent, self-serving and self-promoting ways, all at the cost of failing to contribute to the improvement of the efficiency and effectiveness of Australia's healthcare system, demonstrably and measurably, to the detriment of all healthcare stakeholders concerned, especially the patients going without precious resources, unable to be procured and supplied while NEHTA and its vested interests, waste invaluable time and money dithering in and propagating useless and damaging "spin".

As ‘anonymous’ suspected NEHTA resource postings illustrate, "they" are the ‘smartest guys in the e-health room’, and it's pretty clear from recent history where that all ends up!

The response from the PCEHR ConOps submissions will be telling as to how consultative, engaging and flexible NEHTA are to the views expressed and submitted for this public review.

Anonymous said...

The attitude of Nehta is very like that of the Wall Street investment banks who claimed to have invented a new system of prosperity that would be the best in the world. In those banks the CEO's did not understand the details or complexity of what they were selling or how much risk they were taking with other peoples money. They at least had some short term results to gloat about. They also collected some nice bonus payments to ease the pain.

We also have an eHealth bubble where the DOHA/Nehta CEO's are telling us what a wonderful thing they are building, but the technical people outside Nehta shake their heads in disbelief while Nehtas specifications are made more woolly and full of unessential complexity designed to make it look as if only they can understand the problem. The fact is that there is no demonstrated evidence that Nehta has even a basic understanding of eHealth or any ability to advance it. They have no working specifications in use, in the field, and as a result are positively hostile to anything that is working and try and derail anything that shows up their lack of success. This was clear in the Wave 2 selection process which rewarded only those that were under the Nehta umbrella, or so far from having solutions that they could exercise extreme control.

From a government perspective Nehta has become to big to fail, but fail it will, and I just hope they can pull the pin when its clear to even the casual observer that this is nothing more than a giant PR exercise. Nehta has some talented people, but their ability in influence the organisation as a whole is limited and many good people leave when they realise this. I suspect only a change of government will allow a "correction" as another failure would just add bolts to an already nailed down Gillard Coffin.

Anonymous said...

Saturday, June 11, 2011 9:57:00 AM said "it would appear the 'narcissistic' waters run very, very deep at NEHTA ..."


Unfortunately most people are not trained to identify narcissistic personalities and few [except a psychologist or a psychiatrist] know how to handle them. They are very convincing people - alluringly so. There modus operandi is one of 'destruction' from which they obtain their fulfillment and satisfaction. To the average Joe Blow that seems so negative, destructive and futile - a waste, but to the true narcissist that is 'psychologically speaking' their purpose and objective in life.

Quote from anon - "all at the cost of failing to contribute to the improvement of the efficiency and effectiveness of Australia's healthcare system, demonstrably and measurably, to the detriment of all healthcare stakeholders concerned" .... understand THAT is a narcissist's objective - if they can achieve that they have fulfilled their goal. Eventually they move an and start again somewhere else.

And when you challenge a narcissist they get very angry - it's called 'narcissistic rage'. Their objective in life is to destroy and it looks as though they are doing a very good job of it all round at NEHTA.