Australian College of Rural And Remote Medicine Comments On The PCEHR. Very Interesting Indeed.

This submission was released a few days ago.
Here is the link:
https://www.acrrm.org.au/files/uploads/PCEHR%20Submission%2022.11.13.pdf
Here is the summary:

Summary of ACRRM position on eHealth

ACRRM supports the introduction of Shared Electronic Health Records as a strategy to address the current fragmentation of medical information spread across different locations and providers. This is especially important for rural and remote patients, who are often required to travel to access specialist services, and who are most likely to be transferred away from their local community in the event of a medical emergency or serious illness.

Two new health reports released this week – General practice activity in Australia 2012-13 and A decade of Australian general practice 2002-03 to 2012-13 – confirm the key role of GPs as leaders in primary care in Australia and the preferred first port of call for Australians. GPs must be engaged as a critical player in any ehealth reform. Rural and remote GPs must be specifically supported. It is this group who are faced with the most severe workforce shortages, have the highest patient to doctor ratios and are the most time poor.

The emphasis on the role of the GP in ehealth is appropriate; however more consideration of the role of consultant specialists, nurses, Aboriginal health workers and allied health professionals in their use of electronic records is needed.

General Practitioners strive to provide safe, effective and high quality care within the constraints of a patient consultation. The clinical source of ‘truth’ for patient information today is the patient’s notes, that are either on paper (rare in General Practice now, but still the norm in consultant specialist practice) or in the clinician’s own clinical information system (CIS) or a combination of both.

Currently, the PCEHR is a designed as a tool to share information among providers as determined by the patient. The patient controls what information is shared and which clinicians have access to the information.

When the patient receives care from a range of providers, having access to a tool that provides all the relevant patient information in a concise and reliable format, to all clinicians responsible for the care of that patient, ultimately benefits the patient and the healthcare providers.

This is especially important for rural GPs who provide ongoing care in the (physical) absence of specialists, but often supported with specialist advice via telephone or more recently telehealth arrangements.

EHealth needs to support the sharing of relevant clinical information to relevant healthcare providers responsible for the care of the patient. If this cannot be done in a patient controlled repository then another repository or redesign of the existing solution should be considered.

ACRRM considers that shared electronic health records and the use of secure messaging should be the cornerstone of team based care – which in regional rural and remote areas can be facilitated and optimised via telehealth arrangements. Referral, shared care and handover of patient care can be meaningfully supported by electronic clinical documents, including:

•          Referrals and specialist letter (including versions for telehealth purposes),
•          Hospital discharge summaries,
•          Aged Care transfer documentation,
•          Pathology orders and results,
•          Diagnostic imaging orders, results and images and
•         Prescription and supply of medications (including dispensed medicines) and home medication reviews.

ACRRM considers that there has been reasonable progress in the implementation of a number of foundations to support eHealth nationally. But in recent years there has arguably been an overemphasis on the implementation of the PCEHR at the expense of the broader roll out of the eHealth foundations.

This gap in functionality and red tape being experienced with the implementation of the eHealth foundations needs to be remedied before further investment is made in the national sharing of electronic patient medical records.

ACRRM recommends investment in national infrastructure including a simplified National Authentication system. The College recommends that success is rewarded, and that meaningful use is incentivised. Strengthen investment in clinical information systems (Specialist, GP, Diagnostic Services, Allied Health, Aged Care and Hospital)

Incentivise specialist uptake of eHealth records and continued support of standardised secure messaging and clinical information exchange between care providers.

ACRRM recommends an overhaul of eHealth governance and leadership arrangements to improve transparency, accountability, consultation, strategic development, and implementation. Apply a standards based approach, involve ACRRM and industry and focus on meeting clinical needs, streamlining care and facilitating shared care and handover of care.

----- End summary.

I was very pleased to note how close the recommendations matched my six key points. Even the choice of words is close!

Submission From Dr David G More To PCEHR Review - November 2013

Summary Recommended Way Forward.

1. Major overhaul of leadership and governance of the e-health program to improve strategy, direction setting, standards setting, stakeholder engagement and consultation and transparency.

2. Investment in Clinical Systems (GP, Specialist, Diagnostic, Allied, Aged Care and Hospital) to be strengthened with continued support of  standardised Clinical Messaging and Clinical Information Exchange between care providers. Emphasis on private sector provision where appropriate

3. Continued support of national e-Health Infrastructure (IHI, Terminology, SMD etc.) under the governance cited in Point 1.

4. Competitive development of standards compliant regional health information exchanges to optimise information flows and access for clinicians.

5. Support for voluntary patient access and engagement with clinician systems to facilitate patient / clinician communication, information sharing and co-operation. 

6. Progressive rapid phase out of the current PCEHR as points 2 to 5 are realised. This should happen as quickly as possible given the patient safety risks associated with data quality, incompleteness etc.

----- End quote.

To me what they are saying is that the basics are not yet anywhere near good enough and that is the priority. Could not agree more.

I was really pleased to see the leadership and governance issues get a big emphasis.

I guess it was probably a big ask to hope for a ‘shut it down’ recommendation

All in all a good read.

David.