Sunday, December 01, 2013

Healthlink Ltd - A Major Provider Of Health IT Messaging and Infrastructure in OZ and NZ - Provides A Submission To The PCEHR Enquiry.

I was sent this yesterday and am publishing it with permission.
----- Begin Submission
Dear Sirs,

Re:  Submission to a Panel to review the Personally Controlled Electronic Health Record (PCEHR).

We have been invited to provide follow up comments to our submission to the Senate Enquiry some two years ago.  Over the intervening period, substantial efforts have been mounted to implement and promote usage of the PCEHR.  We note that these efforts have not been very successful, with system uptake and usage data confirming that the PCEHR is yet another poorly utilised national electronic health record system .
Our view remains that the best investment in automating healthcare delivery will made by improving the flow of information between providers; i.e.  following the patient’s journey as he/she moves through the health system, sending and receiving diagnostic and specialist information and enabling patients to be referred by sending high quality information ahead of the patient’s visit to additional healthcare providers.
Our View
Our view is that investment in shared records/centralised records/federated records (as a number of countries and regions have tried to do), is extremely problematic.  We note that in the United Kingdom, Professor Trisha Greenhalgh’s review of the summary care record system highlighted three key deficiencies which conspired to thwart the system’s successful uptake.  Those factors were:
  1. Lack of patient and clinician confidence in the completeness and accuracy of the system and the validity/usefulness of the information held on it.
  2. Mounting concerns at all levels of erosion of patient privacy, in particular the GPs’ concern that they were being asked to ‘bend’ one of the key concepts of the Hippocratic oath by supplying information to unknown parties.
  3. The enormous costs of getting multiple systems enabled to supply data of sufficient quality on a dependable basis.
Our view is that these factors were not considered, nor was there sufficient assessment of international experiences in this field prior to embarking on the PCEHR project.  A spokesperson for DOH said at a conference, when questioned about DOHA/NEHTA’s efforts to apply the many lessons learned from international projects ‘, Australia has a unique set of issues and circumstances.’  That may indeed be the case, but the PCEHR is a very similar solution to the ones developed by many other countries and has achieved very similar outcomes to date to the UK, Canadian and US (state based) systems that have each taken a relatively similar approach to storing and sharing patient records.  Indeed none of these systems has done well and the majority of them have achieved very poor results overall.
We have already provided detailed input as to the macroeconomic approach we believe likely to work and as requested will not reiterate that.  However, at a grass-roots level, we believe that key to success is designing a system that healthcare providers find beneficial in the day-to-day delivery of care to their patients.  A few countries have achieved a high level of information liquidity and this is clearly linked to the efficiency of the health systems in those countries.  A Danish General Practice communicates electronically with 115 other parties in any given month and a New Zealand General Practice communicates with 65.  These countries are achieving high levels of ‘information liquidity’ and they are definitely using IT to improve the efficiency of their systems and enhance the day to day delivery of patient care; benefiting both patients and taxpayers. Currently we believe that the average Australian General Practice only communicates with approximately eight other parties, in stark contrast to counties such as Denmark and New Zealand.
Our View as to How?
In our view, the key to using information technology to improve delivery of healthcare is to organise as much healthcare delivery as possible via a highly efficient primary care-led health system and then to focus on automating it, using market forces to do so. 
In our view, the ideal system will have one party appointed as “steward” of a patient’s primary care records and that parties is then encouraged to allow access to those records on an “as needed” basis.  The approach of appointing a single healthcare provider organisation as steward of a patient’s primary care records is increasingly being followed around the world.  It has a number of benefits including; improved trust amongst patients, especially where that provider is also the patient’s principal provider of primary healthcare services and an increased likelihood that the information contained within the record is relevant, accurate and up to date.
Once all of a patient’s day to day records are being held by their key primary care provider, it is relatively straight forward to design systems that can request information within a security and authentication framework that allows them to do so.  The core patient record is built up with extensive use of secure messaging and a web services based referral framework set up to enable providers to send and receive high quality referral information. 
The availability of a free flow of highly dependable and relevant information makes a huge difference to both the cost and quality of care.
In our view, the Australian health system should fundamentally re-evaluate the current approach rather than simply try harder to make the current system work better.  However well the present system is made to work; its ability will always be limited by its inherent design flaws which require a huge number of systems to send information to a central point, on the basis that the information they send may one day be needed.  This is an activity which busy providers of healthcare will resent being made to do.
Far better, is a system that enables healthcare providers to send and receive information about the patients they are actually treating, including giving providers the ability to interrogate databases on remote hospital and laboratory systems and use that information to better inform their treatment decisions.  Giving healthcare providers the ability to send and receive rich referral information into and out of their electronic medical records systems will provide huge value and process improvement right throughout the sector.
These systems are available now and in widespread use in some parts of Australia and New Zealand.  It is time they were given the opportunity to prove their worth.
Yours sincerely,
Tom Bowden, CEO HealthLink Limited
----- End Submission.
The original January 2012 to the Senate Enquiry on the PCEHR is downloadable from here:

Again we see those on the ground saying the underlying conceptual basis of the PCEHR is simply flawed. I sure hope the Enquiry listens!
David.

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