DoHA / NEHTA Provides Some Analysis on the Submissions Regarding the Draft PCEHR Concept of Operations.

The following appeared in the Google Cache a day or so ago.

Here is the link:

[PDF] PCEHR Concept of Operations Public Consultation Submissions ...

www.yourhealth.gov.au/.../...

File Format: PDF/Adobe Acrobat - View as HTML

PCEHR Concept of Operations Public Consultation Submissions Process: Analysis of Key Themes. 3. 1 Introduction. In the 2010/11 Federal Budget, ...

The full text is currently viewable using the View as HTML link.

PCEHR Concept of Operations Public Consultation Submissions Process: Analysis of Key Themes

Here is the table of contents.

Table of Contents

1 Introduction ............................................................................................ 3

2 Analysis of submissions ........................................................................... 5

2.1 Overview .............................................................................................. 5

2.2 Acknowledgement of submissions ...................................................... 6

3 Process review ........................................................................................ 7

3.1 Overview of the ConOps submissions review process ........................ 7

4 Common themes .................................................................................... 9

4.1 Summary view of themes ................................................................. 10

4.2 Access control, security and privacy ................................................. 11

4.3 General design suggestions .............................................................. 12

4.4 Information model ............................................................................ 13

4.5 Long term governance and sustainability ......................................... 14

4.6 Administrative overhead of PCEHR and remuneration provisions .... 15

4.7 Policy and legislation ......................................................................... 16

4.8 Adoption of the ‘opt in’ model .......................................................... 17

4.9 Implementation planning and road map ........................................... 18

4.10 Rural, aged care, disability and mental health provisions ............... 19

4.11 Secondary use of data ..................................................................... 20

4.12 Legal and liability.............................................................................. 21

4.13 Education of stakeholders ............................................................... 22

4.14 Interest to be more involved with delivery of the e-health System . 23

4.15 Accessibility / Considerations for people with limited or no

access to a computer ............................................................................. 24

4.16 Integration with existing healthcare systems ................................ 25

4.17 Platform mobility .......................................................................... 26

5 Next Steps .......................................................................................... 27

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In terms of frequency of matters raised we had:

Access control, security and privacy - 17.6%

General design suggestions -11.2%

Information model - 9.8%

Long term governance and sustainability -8.1%

Administrative overhead / PCEHR and remuneration provisions -7.2%

Policy and legislation - 6.2%

Adoption of the ‘opt in’ model - 5.8%

Implementation planning and road map - 5.8%

Rural, aged care and mental health provisions - 5.3%

Secondary use of data 4.5%

Legal and liability concerns - 4.5%

Education of stakeholders - 4.3%

Interest to be more involved with delivery of the e-health system - 4.2%

Accessibility / Considerations for people with limited or no access to a computer - 3.3%

Integration with existing health care systems -1.7%

Platform mobility - 0.6%

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So far so good and there are useful things reported under each heading.

What may give a little more pause is this:

5 Next Steps

The draft ConOps document will be revised to incorporate changes based on the themes and key points identified in the public consultation process. The ConOps document is expected to be finalised in August 2011.

Numerous points raised during the ConOps consultation process have been identified as being change and adoption issues. These points will be taken in to consideration by the National Change and Adoption Partner and incorporated into the work being undertaken to plan, design and develop training, guidance and tools in collaboration with healthcare providers and software providers.

Many points also related to the detailed implementation of the PCEHR system, and will be considered as part of the work that is currently being done on the design of the PCEHR’s detailed requirements, and also the work that will be performed by the National Infrastructure Partner. It is anticipated that the lessons learnt from eHealth sites will also be taken into consideration in the detailed design of the PCEHR system.

DoHA and NEHTA will continue to actively engage in a process of ongoing consultation with key stakeholder groups, including consumers, healthcare providers, the ICT industry, and state and territory governments. As part of this process, the PCEHR System: Legislation Issues Paper has been released for public comment and feedback. The paper covers issues such as participation in the system by individuals, healthcare providers and system operators, access controls, privacy, security and governance. Submissions on the PCEHR System: Legislation Issues Paper will be accepted until 5 p.m. AEST Wednesday, 3 August 2011.

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One just wonders just how much of all this is really just ‘kicking the can down the road’ rather than actually changing the overall ConOps to address needed changes. The end of August will tell us I guess.

I note my submission is not mentioned despite the submission e-mail explicitly saying it could be used - it is however on the www.yourhealth.gov.au site. I wonder why it was not mentioned?

I also wonder why the .pdf has disappeared? It was clearly there at one point for the Google Spider to find it!

Enjoy reading the detail at the link above.

David.