Have your say on eHealth legislation: Discussion Paper
Electronic Health Records and Healthcare Identifiers: Legislation Discussion Paper
OverviewThe Australian Government is proposing changes to the personally controlled electronic health record (PCEHR) system, including renaming it the My Health Record system, and the Healthcare Identifiers Service, in response to reviews of each system undertaken in 2013.
The Electronic Health Records and Healthcare Identifiers: Legislation Discussion Paper outlines proposed changes to the legislative frameworks of the PCEHR system and Healthcare Identifiers Service that would support the Government’s proposals.
This paper is intended to provide a plain English description of the proposed legislative changes, and a brief analysis of why the changes are needed. It covers issues such as the establishment of the Australian Commission for eHealth, changing the name of the PCEHR system to the My Health Record system, opt-out trials, obligations of participants in the PCEHR system, and the handling of healthcare organisations’ healthcare identifiers.
The purpose of the paper is to encourage discussion and input from the public on the proposed changes.
You can find out more about the paper by reading the fact sheets for individuals and healthcare providers.
Why We Are ConsultingThe purpose of this consultation is to seek feedback from the community to inform the development of legislative changes
These proposed changes should not be considered final. During the process of legislative development further changes can arise as the result of consultation with the public and government agencies, privacy impact assessments and legislative constraints. The proposals are also subject to Government decision and Parliamentary agreement.
The document is about 32 pages (3 pages of abbreviations at bottom!) and it is really what is missing rather than what is explained here.
First it seems there seems to have been some consultation on the PCEHR Review (that I seemed to have missed) and which came up with some interesting findings
- Individuals and clinicians want to see more representation of their voices and experiences in the ongoing design and implementation of the PCEHR system. They don’t necessarily want a seat on the board of the governing body but do want to ensure that there are mechanisms by which different perspectives, impacts and expertise can be fed into the governance process through effective consultation.
- There is considerable uncertainty in the clinical and vendor community about the future of the PCEHR system. More concrete actions are required to get stakeholders involved in progressing the adoption of the PCEHR system as an ongoing element of the Australian health system.
- Consultations highlighted that knowledge and understanding of the PCEHR system is patchy at best across all stakeholder groups and is particularly poor amongst the general public. While awareness is better amongst healthcare providers, the perception of the PCEHR system is quite poor, and its benefits are not generally understood nor accepted at the current time. Awareness raising will be particularly important ahead of any proposed introduction of an opt-out model.
- In general, individuals understand when the purpose and intent of the PCEHR system is carefully explained. This suggests that an information campaign that is benefits-focused and clear about what they need to do will be necessary.
- Like the general public, clinicians need to see the benefits of the PCEHR system and they need to understand that there is a pathway to improving the functionality and utility of the existing system. They also need supporting materials in order to assist them in discussing the impact of the opt-out model with individuals because the consultation suggests that many individuals will turn to their general practitioner for advice.
- While the majority of stakeholders strongly supported the move to an opt-out model, concern was raised about precisely how an opt-out model might be designed and implemented. Careful design of the opt-out model will be required to manage stakeholder concerns and to ensure stakeholders clearly understand how and why the opt-out model will be introduced.
- While many individuals did not consider that they would necessarily use the access controls and notifications provided in the PCEHR system, they all acknowledged the need for these controls to be retained. Individuals stressed the need for simple mechanisms.
- Meaningful use of the PCEHR system for healthcare providers will be driven by the utility and content of the PCEHR. This will require a focus on improving the usability of the PCEHR system, addressing accessibility issues for those segments of the healthcare provider community such as allied health practitioners who aren’t well served with PCEHR compliant software solutions, and a concerted effort to drive provider participation.
- Most stakeholders were comfortable with the types of content that the PCEHR system can currently hold, however there was concern that very little of this content is being uploaded. It is therefore important to drive population of PCEHRs.
- The introduction of the PCEHR system into clinical practice requires a complex registration process, implementation of new software capabilities and changes to clinical practice. To enable individuals and healthcare providers to start using the PCEHR system they will need access to local support capabilities that will provide the on-the-ground help they need.
- The current roll-out of the PCEHR system seems to have bypassed the private hospital sector. Getting this sector more involved, understanding its drivers and involving its representation in clinical advisory committees will be necessary to ensure completeness of coverage and benefit for individuals.
- Vendors consider that greater use can be made of international standards rather than having to adopt standards specifically designed in Australia. They also want more stability around standards, and want to know in advance when they will be introduced or changed and what they will contain so they can plan their business accordingly”.