Here is my draft submission. Comments are very welcome to improve it.
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PCEHR Review Consultation Submission - DG More - August 2014
Introduction
The following submission has been prepared to offer some commentary and input to the process now underway, being facilitated by Deloitte, to ascertain stakeholder views on the Personally Controlled Electronic Health Record System (PCEHR) and the recommendations of the recently undertaken PCEHR Review which was commissioned by the Federal Health Minister in September 2013 and released publically in May 2014.
Author Of Document
This document is authored by Dr David G More MBBS BSc(Med) PhD FANZCA FCICM FACHI.
I have had over 20 years involvement, in one form or another, in the area of Health Information Technology (e-Health) and been a contributor to many projects in the area including the development of the 2008 National E-Health Strategy.
I am reasonably well known in Health IT circles as the author of a blog on Health IT (www.aushealthit.blogspot.com) which has now been in operation continuously since 2006 and I have been widely quoted in the professional clinical press, the national press and in reports published by the Parliamentary Library.
I have no financial interests in any entities involved in Australian Health IT and receive no payments from the work I undertake in the area.
Over the last 4-5 years I have made submissions in the Health IT domain when requests for such submissions have been made by Government and these are available on the DoH website (www.health.gov.au).
Purpose Of This Document
The purpose of this document is to make one simple point, namely, that to be consulting on the future of the PCEHR, in the absence of the context of the overall Australian Health IT environment, capabilities and requirements, and a current and agreed National E-Health Strategy, would seem to be very risky and dangerous and very unlikely to lead to success with the PCEHR Project.
There are a range of points that need to be made to support this view.
Firstly there is presently absolutely no evidence that in two years the PCEHR - which commenced operation in July 2012 - has made any difference to the quality or safety of patient care in Australia. Indeed there have been essentially zero efforts to assess the impact of the system despite reported investment of more than $1 Billion in the system over the last few years.
Secondly, for reasons best known to herself, the former Federal Health Minister (Ms Nicola Roxon) (advised by NEHTA and DoHA) chose to proceed with an architecture and design for the PCEHR which had never been implemented elsewhere and which had simply no evidence base supporting what was designed and then implemented. Similarly there was no business case developed for what was planned.
Thirdly, as delivered the system has proven to be of little interest to both clinicians and consumers with most consumers being registered and then never accessing the system again. In essence the PCEHR is ‘neither fish nor fowl’ and fails to provide attractive usefulness and utility for any class of user.
Fourthly, there has not been any sufficiently deep process to place the PCEHR in the context of the overall national needs to Health IT and to allocate appropriate priorities for investment based on the available evidence of what works and what doesn’t. I defies logic that this consultation is being undertaken in the absence of publication of a full update of the National E-Health Strategy to inform discussion and assist in direction setting.
Fifthly, it is very unlikely, in my view, that anything other than a fundamental re-design of the National E-Health System is likely to succeed. This would seem to be likely to be very expensive and should only be undertaken in the context of widespread stakeholder agreement and enthusiasm for such a re-design.
Lastly, it makes just no sense to have a consultation process on the PCEHR being conducted and reported to the Department of Health who are the owners of and accountable for the PCEHR. Surely the new Governance Model or similar (as recommended in the PCEHR Review) should have been put in place first and then driven the consultation process?
Concluding Remarks
This submission makes one simple, and to me incontestable, point. To attempt to adjust, modify or fix the PCEHR in the absence of an updated and agreed National E-Health Strategy is pure folly and doomed to fail. It is true there can be many benefits for patient care, patient safety and health system efficiency with properly designed and implemented Health IT. What is presently happening will not have that happen I believe. Six week reviews and six week consultation periods are not the way to achieve the optimal deployment and use of Health IT we all seek. Both DoH and NEHTA have proven themselves to have very considerable difficulties with the implementation aspects of Health IT and to not have a clear roadmap for the future just multiplies the already high risks of failure. It surely is critical the present senior management of Health IT need to go!
I am, of course, more than happy to discuss all the points made here in whatever level of depth might assist the consultation process.
David G More - August 18, 2014.
Post Script:
Among readers of my blog there appears to be a great deal of scepticism that the planned and current consultation is ‘fair dinkum’.
AusHealthIT Poll Number 231 – Results – 17th August, 2014.
Here are the results of the poll.
Do You Believe The Consultation Process Being Conducted By DoH On The PCEHR Is 'Fair Dinkum'?
Definitely 4% (2)
Probably 2% (1)
Neutral 2% (1)
Probably Not 13% (6)
Of Course Not 79% (37)
I Have No Idea 0% (0)
Total votes: 47
Very clear cut. 92% do not think the consultation process is ‘fair dinkum’.
Again, many thanks to all those that voted!
David.
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