Friday, April 08, 2016

The Department of Health Releases A New Draft National Health IT Strategy. How Did They Do? Not Well I Fear.

This e-mail and an attachment were sent out on April,4, 2016.
“Dear Colleague
Attached is a copy of the draft National Digital Health Strategy 2016-2019 (the Strategy) for your review and comment. This Strategy has been developed in order to replace the previous 2008 National eHealth Strategy. The Strategy, once fully developed will be presented to the Australian Health Ministers Advisory Committee (AHMAC) before being recommended to the COAG Health Council for endorsement. This version is an early draft which not yet been considered officially, and as such does not currently have any formal status. We also appreciate that there is still work to be undertaken on the presentation of the document.  What is important, at this stage, is to gain your feedback in relation to the content of this document.  We are sending you this draft as part of a closed consultation process, and ask that you limit distribution and discussions on it to a representative group of your members at this stage.
The Strategy aims to recognise the need for increased collaboration across governments, healthcare providers, healthcare consumers, the private sector and software vendors to deliver an integrated digital health eco-system that supports healthcare provision within Australia. While it articulates the government programmes to be delivered, it's intended to provide certainty for private sector technology and innovators to encourage and foster innovation by the non-government sector. It acknowledges the need for real, consistent and ongoing engagement with consumers and healthcare providers in the design of digital health solutions.
The Strategy acknowledges the health system is changing rapidly, with new models of healthcare being regularly developed in response to opportunities, challenges and demands on the health system. Many of these changes are being driven by improved use of data.  Technology is also rapidly evolving, and consumer and healthcare provider expectations of digital health solutions are increasing as they are exposed to advanced innovative solutions in other sectors such as retail and banking.
We will update the Strategy based on the comments that we receive from you and others during the consultation period.  Once the Strategy has been endorsed, the Australian Digital Health Agency will take responsibility for the ongoing development, coordination and implementation of the Strategy through the National Digital Health Work Programme.
Any questions, comments or feedback that you have on the Strategy should be forwarded to James Robertson at by 14 April 2016.
Paul M.
Paul Madden
Deputy Secretary and Special Adviser
Strategic Health Systems and Information Management
----- End Extract.
As you might expect I have had a number of copies forwarded to me as I was not on the original distribution list. (the full distribution list was provided to all recipients in what seems to be a minor security leak).
I have read the document through and have contributed my thoughts to one of the groups who were asked to respond. Sadly I can’t reproduce the document on the blog but I have made it available here for download:
I am making this file available to readers as I see them as part of a special group who have a major interest in the future of Digital Health and who need to have a say.
My thoughts are in 2 parts. My general response is that the present document has a very long way to go before it could be considered even vaguely satisfactory.
As far as specifics are concerned I would make the following points (in no particular order):
First I believe there are so many gaps in the work I believe the document is not really worthy of being described as a strategy - it is more just a really unconnected series of assertions and desires.
Second the document lacks any real insight into the current Health IT situation in Australia, especially it largely ignores the wide range of successful private sector initiatives.
Third, there is no clarity provided as to just who the intended audience for the strategy is and just who are to be assisted and supported by the plan. Is it for clinicians, consumers, the jurisdictions the Department of Health, the private sector or a mix/combination of all of the above or something else?
Fourth, as previously noted in this blog almost decade ago, a strategy without a funding plan and commitment is the emptiest of strategies / plans.
Fifth there does not appear to be anything that could be described as an implementation plan.
Sixth the current document totally fails to review the 2008 National E-Health Strategy to draw  lessons on just what matters in actually delivery of a Strategy and fails to analyse where the successes and failures lay and why.
Seventh it is clear that the present document has been inadequately consulted on with many stakeholders largely ignored and no real consultative processes conducted, with an overwhelming predominance of Government staffers.
Eighth the document is excessively focused on the myHR and while recognising it is not fit for purpose - suggests the need to press on while trying to fix it. If ever you saw a chicken and egg problem - this is it!
Ninth the current document  fails to grasp that Health IT needs to clearly recognise at least two customers - of which the health care providers are the most important - for the strategy (the other is the public/consumer). It is not clear the same solution can work for both classes of stakeholders.
Tenth the document is really weak on evidence, benefits analysis, overseas research and a realistic technology assessment and future analysis.
Eleventh there really is not a clear strategic situation assessment and a future vision.
Last it is not clear just how this document relates to the nascent Digital Health Authority - which is meant to be a strategic organisation.
Overall this document has a very long way to go I believe before being a half useful contribution to the state of play.
I would ask that those who are interested download the document and comment - I am sure DoH will have someone having a browse of the comments!


Anonymous said...


I have downloaded the document and thank you for making it available. Regardless of its merits or otherwise it is important that your readers also download the document. I

It is disappointing, but to be expected, that distribution of the document has been curtailed by the Department rather than made more widely available (it should not be a problem that it is a rough draft).

Where the problem lies is that the Department should be openly and genuinely seeking to obtain the maximum viewpoint / opinions possible, as grist for their mill. That it has not done so is more than a little troubling.

I doubt the Department will try to have you remove the document from the link you have provided, but one cannot be certain. I think their hearts are in the right place, although it does seem that they lack the confidence and maturity to make the document openly available and to welcome input from all interested parties.

I have read your initial first pass comments which all seem to be balanced and reasonable and with which, at this stage, I have no argument. This view may change however after I have carefully read the document. If so, I'll let you know, via this blogspot.

Dr David More MB PhD FACHI said...

Thanks Anon,

They are dreaming about this being taken down. It is hosted in the US. Anyway love the way you are so confident you can add value to my comments. Look forward to that.


Bernard Robertson-Dunn said...

I have been told that it wasn't a security leak, the Department did it deliberately to show how widely it was consulting.

FYI, I'm helping to put together the Australian Privacy Foundation's response, we hope to circulate a draft copy to the full distribution list on Monday morning.

The APF has a few concerns with the document, not the least being that it seems to have been done in isolation with no reference to the previous strategy, to the opt-out trials or to the significant feedback the Department's had over the years.

There's also the scope. It contains this sentence:

“The Internet of Things offers real potential to have a major influence on revolutionising healthcare delivery.”

Then carefully (or absentmindedly) ignores the "real potential". The only other mention in the whole document is in the glossary.

Anonymous said...

Dear David
Thank you to giving air to the draft of this long overdue document. The 2008 Deloitte document still on the DoH website still acts as the road map for ehealth. Since 2008 smartphones, tablets and many technologies are changing or "disrupting" (if you prefer) healthcare in ways unimaginable 8 years ago.
Over 90% (if not all) of those already consulted come from government and on a government payroll. If this is their best effort at a strategy document...where a strategy according to most definitions is "plan of action designed to achieve a long-term or overall aim" then we are all doomed.

Bruce Farnell said...

Dear David,

Thank you for providing the link to the document.

From my cursory examination I was disappointed. However, my hopes were not high. As a strategy document it falls way, way short of the mark. It seems to me that the purpose of the document is not so much strategy but justification of 'business as usual'.

Some of the preliminary sections were OK - as far as they went. As others have noted there was no or limited assessment of initiatives outside the sphere of the Department of Health. However, that can be fixed. Also, there were many untested assertions as mentioned by others.

My concerns are to do with the 'missing parts' of the document. Where is the detailed analysis? Where is the discussion of options? It just sets sail into what the PCEHR (sorry MyEHR) 'provides' assuming that all is good and wonderful. Goodness only knows what they are going to do if or when the myEHR finally fails officially. The other initiatives mentioned are like a grab-bag of initiatives. How do they fit together? Where are the gaps?

Despite all of this, my biggest problem with the document is that it makes no real attempt to refocus and elevate the visibility of the critical issues so that we would need to develop and monitor KPI's on them.

Off the top of my head I have two.
1. Patient Safety.
2. The unsustainable growth in the cost of healthcare in Australia. (or how can we do more with less.)

That's my 2c worth. Not bad for 5mins.


Anonymous said...

Hi David, thank you for sharing this document, could you confirm this was not released as an April fools prank? I am really hoping it is, that or it is being used to demonstrate why we should invest a few million on people who have the skills to formulate a national strategy. if the list of contributors is what has been leading ehealth to date it is no wonder we are in a slump.

Dr David More MB PhD FACHI said...

Nope - sadly it is all real - for those who invented what we have.


Anonymous said...

On the upside, it makes Deloitte look good and should save some hiring managers a bit of time.

Anonymous said...

Tenth, it states for review and feedback in a closed consultation, there are no consultation points in the document to draw out specifics and engage the collective wisdom and views of those being consulted. My assumption is this is perhaps being done without the taskforce and Richard Royal blessing, if it is then it has put the new Digital Health Agency on the back foot and facing a steep and rocky climb if they are looking to break from the past.
Smell of desperation from those wishing to look relevant, yes those same ones who have done so little with so much for to long.

Anonymous said...

Thanks David ...what a wonderful service you provide the community in distributing this document. I have read the document and comments from this blog and others.

I would say that most people (including myself) are profoundly unimpressed with the content, however as some have noted in the comments to your blog thus far, there is an alarming aspect to the "staging" or sequence of events that have culminated in the production of this document, which needs to also be discussed openly in public. These concerns include:
1. Substance - the document is lacking the rigour, analysis, vision, content and detail that you would expect of a strategic plan
2. Process - the "consultation" conducted is deficient, biased (towards government employee contribution) and very limited in scope and duration. Engagement of the real stakeholders is missing in this process
3. Governance - given that he ADHA is not even properly constituted yet (an acting CEO with no board or permanent appointed executive team at this stage) and will (presumably) be responsible to COAG for the development and delivery of the national eHealth / DH strategy, why is the Department of Health producing this document and rushing it to get endorsed by COAG before the ADHA is operational and is in a position to properly conduct a strategic planning process - determining the scope, process and content of the plan etc ? One can only assume that the real agenda is to make sure that the ADHA has the shackles on before it get started !!

Anonymous said...

It seems Paul M. - Paul Madden - Deputy Secretary and Special Adviser - Strategic Health Systems and Information Management has overseen this process (someone has to be in charge). If so he needs to start paying some serious attention to the various comments now being made.

As 10:25 am said ..... the "consultation" conducted is deficient, biased (towards government employee contribution) and very limited in scope and duration. Engagement of the real stakeholders is missing in this process".

It matters not that it is a DRAFT document or that it might be changed in response to input from all manner of sources.

What really matters is that the document patently shows great shallowness, paucity of insight and an inability of the contributors to realistically comprehend the 'eHealth marketplace' in all its dimensions including cultures, politics, participants and stakeholders.

Most of the 'contribution' and 'commentary' seems to have been compiled by bureaucrats as listed in the Appendix! Is there any other explanation? No doubt, if one could examine their CVs, we would understand how this document came to be "so lacking the rigour, analysis, vision, content and detail that you would expect of a strategic plan (10:25 am).

Anonymous said...

Re 10:25 AM and 1:26 PM - I think the root cause to account for what you both say is a combination of power, hubris, arrogance, inexperience and an unbridled belief in their superior capabilities, which means that they won't take any notice because, on past evidence, notwithstanding all the excellent submissions organisations and individuals have made, similar bureaucrats never have taken any notice and therefore they probably never will (leopards' spots don't change ....).

Even so, there is a slim possibility that Paul M might appreciate the wisdom of some commentators and decide to actually start listening; depending of course on whether he has the flexibility to do so, who is advising him to the contrary, and what untold pressures are being brought to bear upon him to show that he can get results.

Does he understand that he can get results faster and at less cost with a different approach? I think he has the intelligence and capacity to view things differently, but he might not have the flexibility.

Anonymous said...

Paul Madden:

A project manager & Program Director (a glorified project manager)

"Prior to joining the Department, Mr Madden was Program Director of the Standard Business Reporting (SBR) Program led from the Australian Treasury from 2007 - 2010."

A piddling little project involving collecting standardised documents from various business. Off the shelf software, tailored to meet Australian requirements.

Make up your own mind if you think a) he has the background and training to develop and execute a national health strategy or b) the wherewithal to "appreciate the wisdom of some commentators and decide to actually start listening"

Anonymous said...

I have just found the time to read it and its clear that they don't realize that there is already a disruptive technology at play and its them. They are leading us into the marshes with no solid ground in site and pretty soon their snorkels will go underwater.

It seems they have enough knowledge to realize that mobile phones are pretty cool, but no amount of clever app building will lead to seamless healthcare unless the providers have solid systems with high quality data and working decision support. Maybe they have signed a contract with IBM to license Watson to read all the pdfs in the PCEHR and collate peoples diagnoses and medications out of a pile of opaque pdfs. I guess there is a small chance that could work!

Every service that has been "delivered" is highly flawed at its conceptual stage and not fit for purpose. They have done nothing to improve the day to day quality of care by providers and what have been positive has been delivered by organizations outside the grip of their toxic culture, or at least resistant to their influence.

This document deserves a place in the Dilbert Hall of Fame as a fine example of the pointy haired boss "plan". Dilbert would find a way to ignore it and do some useful work despite the pointy haired boss and dogbert and the software industry has to find a way to do the same. I think The new agency should go and check out the Elbonian eHealth department for some tips on the best way backwards.