Sunday, September 29, 2019

The Request For Information On The Future Support Of National Digital Health Infrastructure Is Just Amazing!

Reading the RFI document I found this list of key technological themes very interesting.
Here is the link:
https://www.tenders.gov.au/Atm/Show/c120551a-5788-49ac-bae4-7ef26e867c07

Part E: Key Themes

Since its formation the Agency has been undertaking or has participated in a range of consultations and market research which have included consideration of future technologies and capabilities. A number of themes have emerged that may impact the technology and capabilities within the national infrastructure.
This document provides a high level overview of these key themes. It is not exhaustive and is provided as lists (in no particular order) that Participants could consider as part of responding to this RFI. The list is not intended to be a definitive list; the Agency intends to consider all themes for the future, including those identified through the RFI process.
This document does include all of the areas that have emerged through the national conversation about interoperability. Information about this conversation can be found here: https://www.digitalhealth.gov.au/about-the-agency/digital-health-space/interoperability-better- connections-for-better-care.
Global Themes
Identified global themes from a technology perspective include:
·         Block chain and Healthcare - Investment towards block chain technology to underpin the future of EHR systems to drive the future of Healthcare record keeping.
·         Technology Investment - Greater focus in technological investment to reduce costs, improve access and care. E.g. redefined care delivery in hospitals through AI and talent development, as well as reshaping healthcare treatment.
·         Increased Healthcare Demand and Spending - Increased demand and spending are forecasted for the next decade. Need to focus on a EHR system that seeks an efficient and cost focused system.
·         Person centred Healthcare - Heavy focus and demand on individualised healthcare, which challenges the efficiency, demand, and innovation across electronic healthcare. This is seen through customer apps, patient portals etc. to work alongside healthcare
·         Industry wide issues - Escalating cost, inconsistent quality, and lack of access to timely care. Progression of modern web service standard approaches such as the Fast Healthcare Interoperability Resources standard
·         Data processing - Efficiencies in data processing have been realised from constant development in computing allowing a reduction in data traffic.
·         Privacy and Security - Greater focus on privacy and security from consumers for all personal data.
·         Information On Demand - Consumers are demanding access to healthcare information on demand. This is leading to more IT and digital focused environments.
·         Internet of Medical Things (IoMT) - This connected infrastructure of medical devices and software applications could have implications on timely, quality care & information sharing.
·         Technology and Innovation in Treatment - Innovation and technology in treatment development emphasises the need for accurate, accessible, and complete EHR for all patients.
·         Demand for Infrastructure - ICT infrastructure and its scalability are trend areas that are increasingly important.
Future concepts
Feedback suggests that there is a need for an enhanced user centric environment that is a responsive and seamless system based upon end to end User experience. Opportunities for innovation and interoperability need to be considered.
Themes raised include:
·         Open architecture by establishing a system with open software defined architecture that provides the flexibility and scalability required to respond effectively to increases in the usage and storage needs.
·         Interoperability through integrated standards based platforms which support interoperability and the sharing of data for primary and secondary use.
·         Breaking the clinical ‘document paradigm’ with a greater emphasis on capturing structured data, better managing unstructured data through defined classification standards and applying analytics to better understand social health.
·         Digitally Enabled solutions through exploitation of digital services delivery forms such as Bots, Artificial Intelligence & Machine Learning, Big Data, Internet of Things, Blockchain and Mobile Applications to facilitate access, data collection, management and utilisation of data.
·         Collaboration through enabling multiple stakeholders to work together in a coordinated approach to optimise clinical and operational effectiveness.
·         Engaged Talent through building an internal innovation capability to enable the development, testing and implementation of applications in response to User needs
·         Placing the consumer, whether patient or provider, at the centre of all design to achieve personalisation and adoption.
·         Ease of use equals trust in software and the related systems.
·         Consumer Benefit - access to your data in dynamic and insightful ways.
·         Accessibility - Interfaces optimised to provide access for all consumers including those with special needs and language barriers.
·         Multi-Channel – the ability to engage across multiple channels, which are likely to change over time (e.g. an API-led, multi-vendor ecosystem).
·         Buy-in - trust in the system, the security and management of data is critical to use
·         Consumer Visibility - making health data discoverable and enabling users to create content
·         Secure & Private through employing technology to maintain data privacy and security (cybersecurity), are foundational to the system. This technology would secure and support the system by proactively identifying and responding to potential threat. Security and privacy also includes:
·         Transparency and confidence in the security of the system being critical to maintaining consumer trust and engagement.
·         Any system must be ‘secure by design’, i.e. from the beginning the system and software is designed to be secure.
·         Security and Privacy must be supported by standards and policy to drive transparency, visibility and accountability.
·         User control to address consent and access issues.
Potential Technology Trends
Potential next generation technology considerations could include:
·         Blockchain use has been raised as a key next-generation technology
·         Robotics & Artificial Intelligence have been raised as next-generation trends
·         Big Data & Analytics through the use of high performance analytic systems capable of collecting, organising and analysing large sets of data (structured & unstructured) from multiple sources to discover patterns and trends to improve social health and shift to a ‘push/pull’ ecosystem
·         Internet of Things (IoT) by exploiting the network of intelligent physical devices that enable the exchange of data
·         Cloud computing through use of open architecture technology models and computing to support system interoperability, scalability, analytics & innovation
·         Mobility and Portability through applications deployable on different device types, for consumer usage and management of their Health Data.
·         APIs - Developing smart API’s and an API strategy are integral to evolution of access and information (specifically data access policies).
The general questions asked of responders were basically as follows.
1: Please describe what you see are the design considerations for future updates and improvements of the national infrastructure that supports the digital health products and services delivered by the Agency. Please include how you consider catering for future expansion, scalability and emerging technology areas.
2: Please outline the technology focus areas (including new or emerging technologies) that should be considered to keep pace with the latest developments (including standards).
3: Please outline your view of priorities for the future of the Agency’s digital products and systems (including technologies) and how you consider the Agency could drive efficiencies in the total cost of ownership):
4: What capabilities do you think might be required for the future success of the national infrastructure?
5: What factors do you think should be considered for inclusion in the future development of the national infrastructure?
----- End extracts.
Essentially what we have here is a totally incoherent and nonsensical farce. Absent any context as to what is expected of the so called “National Infrastructure” people are asked to comment on a large range of technologies and where they think they might fit in the future - unspecified.
Other than the tech wish / fantasy list, the rest of the document is a set of puff pieces on how wonderfully the ADHA is doing – with very little evidence – and the usual Government guff of how to respond and how they virtually own any ideas you offer!
There is nothing I could see on what the project objectives were, what sort of technological future might be preferred, how it was to all hang together, what sort of Budget was envisaged, what usage was expected, what use cases were seen as relevant and so on.
Were I responding to this I would want a detailed analysis of technology status at present, what were seen as the issues and limitations etc., and real usage stats on what was being used and so on to provide a base from which to build some sort of realistic technology future. It is also not made clear whether evolution or replacement is sought as far as I can see. If a new bespoke system is needed to replace the old one that will be both slow and expensive and to just evolve probably won't fix much!
Overall, I really suspect that this document might just be a con. The ADHA has a tech path it wants to follow and is seeking to have the industry agree – and in due course will tell us all what is planned. If this were not the case the ADHA would have opened the kimono properly, identified all the issues it was facing and be asking for providers to suggest coherent ways forward.
Remember this is all meant to be up and operational by, at worst, the end of 2020 when the Accenture contract ends. Fat chance!
David.

16 comments:

  1. This tweet says it all - he studied history

    https://twitter.com/tkelsey1/status/1176447494277873664

    From the head of a Federal government agency who should be showing leadership in technology enabled healthcare.

    The RFI just confirms he knows nothing about either technology or healthcare - or how to run an agency

    He may think his tinpot little agency is world leading - the reality is that the rest of the world is just laughing behind his back. They are learning from his mistakes, he isn't.

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  2. Blockchain?? And no mention of Fog Computing. Would not ask ADHA to run a bath.

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  3. ROTFLMAO.

    That's about it really. Compared to the original RFI which had substance this is garbage.

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  4. Or in the editor and thief native tongue - PMSL.

    You are correct in that the content falls short as a industry briefing. Fortunately, the Accenture’s and KPMG’s type consultancies have legions of minions able to turn this around and present an answer the both stokes egos, provides the minister some new motivational messages, a horizon Beyound his care and the department a means to continue to pay to be part of the health conversation.

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  5. How about requiring implementers to comply with standards they already use? Then everyone can transmit data secure in the knowledge that if they construct the message properly it will be handled and displayed correctly at the other end of the transaction?

    That's about all the government help we need, apart from making identifiers like provider numbers available and to stop trying to do things like terminology that they are hopeless at. Really they just need to say, "This is health data and peoples lives might depend on it so it has to be compliant" and get out of all they stuff they are hopeless at, Is there anything they have done that has been well done? Nothing comes to mind.

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  6. It looks like 90% of what is listed above was asked for by potential users (clinical, research, patients etc) and promised by NeHTA more than 7 years ago (some at NeHTA's inception). Progress appears very slow and promised benefits are still unrealised. Promised savings should have been visible and more than able to pay for continuing the operation. Interoperability is not just "computer-to-computer" but also requires "person-to-person" implementation of standards for quality, completeness, context and understanding.

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  7. Bernard Robertson-DunnSeptember 30, 2019 5:20 PM

    The usual mantra is "the right information in the right place at the right time."

    The trouble is, no-one has answered the question "what is the right information at a particular place and time".

    The ADHA hasn't a clue and has gone for something they call a summary (but isn't) combined with some very low level data with no context.

    Even the original aim - to join up existing data - is simplistic and has more downsides than potential benefits.

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  8. @%:20 PM How would you answer the question"what is the right information at a particular place and time".

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  9. Bernard Robertson-DunnSeptember 30, 2019 7:37 PM

    'How would you answer the question "what is the right information at a particular place and time".'

    Good question. A question that the people who claim to be able to do it need to answer.

    IMHO, the right information is the information acquired and used at the place and time of care, not historical information.

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  10. @&:37 PM ... surely you are not saying that historical information is of no value? Allergies, Past Operations and illnesses, past tests like changes in creatinine levels, HbA1C, Hb, WCC, etc.

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  11. @10:33 PM. Information is useful if presented well-off human decision making. Currently the data provided by ADHA systems is bloated and locked up in unstructured documents. Sure they can pull the wool with a few tricks with viewers but reality is that is limited. We already know that an undisclosed number of records are rejected or do not find there way to the myhr digital cardboard storage boxes.

    As Andrew points out without conformance software and compliance to standards it is all bollocks. The trouble is ADHA software is no longer safe or standards based so they will never fix things and allow a level playing field.

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  12. Bernard Robertson-DunnOctober 01, 2019 9:40 AM

    "surely you are not saying that historical information is of no value?"

    All information has potential value, but always comes at a cost.

    The value is dependent on factors that include context and relevance.

    It is a characteristic of humans that they are constantly changing - as they age, react to their environment, modify their behaviour, exercise, diet, etc.

    My argument is that the most valuable is at the time and point of care.

    The big problem with historical data is that it needs validating. The MyHealthRecord.gov.au site used to say

    "How can I be sure information in the My Health Record system is up to date?

    Clinical information you find within your patient’s My Health Record should be interpreted in much the same way as other sources of health information. It is safest to assume the information in a patient’s My Health Record is not a complete record of a patient’s clinical history, so information should be verified from other sources and ideally, with the patient."

    This advice, along with other advice has since disappeared from the current site.

    The ADHA seems to have gone out of its way to remove anything that might be seen as a weakness or is critical of the system.

    However, the website has been archived, so the ADHA can't completely hide from reality.

    The above quote is from a page available from an archived version of the site.
    http://web.archive.org/web/20170425172312/https://myhealthrecord.gov.au/internet/mhr/publishing.nsf/Content/healthcare-providers-faqs

    The home page is here:
    http://web.archive.org/web/20170420060857/https://myhealthrecord.gov.au/internet/mhr/publishing.nsf/content/home

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  13. Bernard Robertson-DunnOctober 01, 2019 10:38 AM

    and while we are on the subject of allergies and confirming a diagnosis with patients:

    Overdiagnosis of Penicillin Allergy Leads to Costly, Inappropriate Treatment
    Rita Rubin, MA
    November 13, 2018
    JAMA. 2018;320(18):1846-1848. doi:10.1001/jama.2018.14358

    Penicillin is an oldie but a goodie in the armamentarium for treating bacterial infections.

    But, in part because it has been widely used for decades, penicillin is also the most commonly implicated medication when patients report a drug allergy. Approximately 10% of US residents have been labeled as allergic to penicillin, often since childhood.

    Yet, a growing body of evidence suggests that as few as 10% of people who report they’re allergic to the antibiotic really are.

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  14. The ADHA seems to have gone out of its way to remove anything that might be seen as a weakness or is critical of the system.

    Interesting observation, Bernard. Does make one wonder if by removing these disclaimers and advisory statements, the ADHA is setting itself up for legal battles in the future? After all, they can be sued. Wonder why their General Counsel would permit this? Or has legal advice been ignored the same way privacy, clinical safety and software architecture has?

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  15. Bernard Robertson-DunnOctober 01, 2019 3:17 PM

    The sort of information that is now not provided to Health providers (and of course the general public) is this:


    I am a General Practitioner, can my staff access a patient’s My Health Record if I am at hospital and not at the clinic?

    Yes. The staff at your Healthcare Provider Organisation can access My Health Records as long as they are authorised users, even if they do not have an Healthcare Provider Identifier-Individual (HPI-I) identifying them as a healthcare provider. The My Health Record system entrusts a participating organisation to grant access to ‘authorised users.’ An authorised user must be an employee who has a legitimate need to access the My Health Record system as part of their role in healthcare delivery. When authorised users without a HPI-I access the My Health Record system, they are only permitted to access the records of patients with whom they are involved in delivering healthcare services. All access to the My Health Record system is with the patient’s initial consent and is audited. Authorised users without an HPI-I cannot be listed as the author of a clinical document submitted to the My Health Record system.

    http://web.archive.org/web/20170216140022/https://myhealthrecord.gov.au/internet/mhr/publishing.nsf/Content/healthcare-providers-faqs?OpenDocument&cat=Healthcare%20Providers

    There may be some justification in removing certain data as the functionality changes, but the examples I've cited are still relevant.

    This fundamental claim has never been true, so it's not surprising it has been removed.

    "Available to all Australians, My Health Record is an electronic summary of an individual’s key health information, drawn from their existing records and is designed to be integrated into existing local clinical systems."

    Data is uploaded, not "drawn from", a function that was specified in the ConOp but never implemented.

    And this has also disappeared

    "A nominated healthcare provider is decided by mutual agreement between the healthcare provider and the individual." There is nothing about "mutual agreement" on the current site.

    http://web.archive.org/web/20170425172312/https://myhealthrecord.gov.au/internet/mhr/publishing.nsf/Content/healthcare-providers-faqs

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  16. Bernard Robertson-DunnOctober 01, 2019 10:45 PM

    Other information that does not seem to exist on either www.myhealthrecord.gov.au or www.digitalhealth.gov.au are the reports from the Australian Commission on Safety and Quality in Health Care

    There have been ten clinical safety reviews of the My Health Record System. This is a link to the summary of the tenth

    https://www.safetyandquality.gov.au/publications-and-resources/resource-library/tenth-clinical-safety-review-my-health-record-system-summary-report

    It's interesting that the terms accuracy and completeness do not occur in the report.

    The Event Summary has come in for repeated criticism, but nothing much seems to have been done about it.

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