Sunday, June 21, 2015

Isn’t This Just Typical Of How The Department Of Health Treats The Health IT Sector.

Recently Submissions to a Senate Enquiry have been opened on the National Health Amendment (Pharmaceutical Benefits) Bill 2015.
You can read the Submissions that have been received here:
Submission 20 came from the Medical Software Industry Association (MSIA)  
Here is their Submission dated 19 June, 2015.

National Health Amendment (Pharmaceutical Benefits) Bill 2015 [Provisions]

The Medical Software Industry Association (MSIA) is an industry association representing software vendors who develop software for healthcare. Amongst our members are all software vendors who provide software for community and acute pharmacy. That software incorporates the monthly PBS updates, claiming and other information that supports pharmacists in their dispensing role such as patient information sheets, safety alerts and decision support.
Implementation Issues
The 5th Community Pharmacy Agreement, (5CPA) provided a transition timetable to the 6CPA where work on the transition and roll out could begin early April. However, this was not possible and the 6CPA was only made publicly available on the 28th May. To implement the government’s policy changes for the roll out on 1st  July, dispensing software vendors needed to have business rules on which the software code must be based and a vendor test environment in place as soon as possible. The business rules were made available on 12th June with further clarification on the 16th June. The test environment will be made available by DHS on Monday 22nd of June.
In addition because there is no 100% guarantee that the bill will pass the vendors need to ensure that they are ready for either a continuance of the 5CPA or the new and much more complex 6CPA. If the Bill is passed on the 24th or 25th June then the software vendors have only three or four working days in which to complete their preparations. This is means that not all software vendors will be ready to implement all programs on 1st of July. Normal development cycles require at least 6 weeks and more for the complex changes that are required for the 1st  of July.
This means inconvenience, confusion and a messy change-over for pharmacy, their patients and the software vendor community.
Our concerns are highlighted by the fact that on the 10th of June the Department of Health wrote to the Pharmacy Guild of Australia informing them that the Department of Human Services ‘would not be able to automatically process a component of the Administration Handling and Infrastructure Fee (AHI) until July 2016’. We now know that DHS is going to manually reconcile some 4 million scripts until they are ready to automatically process in July 2016. We find it extraordinary that this government is passing legislation its own agencies cannot implement in an appropriate (21st century) way.
The software vendors will be implementing the whole AHI in order to support our clients as quickly as they can, but final reconciliation for July scripts, by DHS, for example, will be delayed until October 2015.
It is also noted at the time of writing the pharmacy community had not been made aware of this issue and the impact it is likely to have on their administration, cash-flow and increased complexity of daily workflow. No communication has been made to pharmacists about the inability of DHS to process some part of the new programs.
In addition the MSIA, despite representations to the Minister’s office had not been one of the stakeholders “consulted” during the 6CPA negotiations - such policy roll-out is dependent on the co-operation of the dispensing software vendors and we recommend they are consulted during the 7th CPA negotiations.
Recommendation: That the Senate consider delaying the implementation of the AHI component of the Bill until all the stakeholders are in a position to facilitate a smooth and seamless ‘go live’ where the dispensing vendor and DHS automatic payment capabilities align OR delay until October when DHS’s manual reconciliation processes will be ready.
----- End submission.
So the bottom line here is the Senate may or may not pass some legislation for implementation a week  or so later and the providers of the dispensing software will simply not ready and pharmacists and consumers will potentially disastrously disadvantaged.
Better still the MSIA has not even been consulted and neither have the pharmacists - who may have their businesses seriously disrupted by all this!
It seems to me the Minister and Department better lift their game - and soon!
What a farce from the Department that brought you the PCEHR!


Oliver Frank said...

I have told audiences of GPs for years that the government treats software vendors worse than it treats GPs, and this is another example.

Karen Dearne said...

The DHS is going to manually process 4 million scripts because it cannot fix its own systems for another year? What a farce! How much is it going to cost to staff this enterprise?

Presumably the extraordinary haste to hold the briefest ever inquiry into a complex piece of legislation is due to the government’s inability to get its act together before the conclusion of the fifth CPA - and the legal abyss before commencement of the sixth.

I have never seen such a rushed inquiry - legislation referred on June 15, submissions close June 19, committee due to report June 23. Seven days!

Congrats to those 23 organisations that managed to do a submission and those few who fronted a public hearing on Thursday. The transcript is not yet available on the committee page (no hurry, there) but were published Friday here;adv=yes;orderBy=customrank;page=0;query=Dataset%3AcomSen,estimate;resCount=Default

No doubt committee members spent the weekend digesting this material and are ready to write their report and make their recommendations today.

Surprising, really, as there are a number of issues in this legislation that should be examined more closely - particularly in the light of the scathing audit report on Health’s management of the agreement - such as location rules and pharmacy community initiatives.

And what about allowing pharmacists to substitute biosimilar drugs to patients without reference to prescribing doctors - the main issue picked up in submissions - surely a potentially disastrous scenario?

Bernard Robertson-Dunn said...


Governments in general and this one in particular, are not big on thinking things through based upon evidence, analysis, logic or expertise. So this should not be a big surprise.

The only thing that matters is action. They believe you don't make progress my thinking about things, only doing things.

Maybe someone actually tried to think about this, but were told that thinking time was up and they really had to do something because nobody had planned things properly and existing agreements were about to expire.

Anonymous said...

We are ruled by rent-seeking dysfunctional bureaucrats that seek to control the enormous investment $$$'s committed by private enterprise.

They court, encourage and seduce the innovators until they pass the point of no return and then throw a mighty spanner in the must change if health is to be dragged into the next generation.

Anonymous said...

The rent-seeking dysfunctional bureaucrats have long seduced, courted and encouraged innovators to invest heavily in health/pharma software solutions.........then do everything under the sun to restrict the commercial opportunity of investors.

We will never have a properly functioning system while tin-eared politicians listen to the appallingly advice provided by bureaucrats and the grand tree of 'all care, no responsibility' exists.