The Industry Raises A Few Questions On the COAG Outcomes.

An experienced industry participant and observer sent along the following a few days ago.

It seemed to me there were some interesting questions to which I had not much in the way of answers. So with permission here it is.

----- Begin E-Mail

Hi David

I think the COAG outcome has some significant ramifications for NEHTA, in that it has already been given whatever money it is going to get for quite some time

- hence it had better use it expeditiously

- with the new arrangement some of that money might possibly evaporate (but I doubt it)

Now that the Feds are to be responsible for funding ALL 100% of the Primary Care sector plus 60% of the hospital sector why should the states continue to pay 50% of the cost of funding NEHTA?

And take THE BIG projects like Vic's HealthSmart. What does the new COAG agreement do to the development and service delivery model of the one-size-fits-all approach of HealthSmart?

Is this a good time to stop for a rain check on IT development in health in each state?

In Vic does the HealthSmart strategy complement the concept of PHCOs and Hospital Networks as envisaged by the Rudd government?

Does each state need to develop a 'different' Hospital and Primary Care IT strategy or should the same strategy apply to all?

Who should be funding (this) these strategies?

Where does NEHTA fit?

What does it mean for the health software vendors?

Is it business as usual for the foreseeable future or is it timely to review the status quo pronto before events of recent days unravel too far?

I mean, let's face the fact(s), 'for health reforms to be effective they must be underpinned by the delivery of fast, high quality, integrated, health software solutions across the whole of health.

Should Australia be waiting for NEHTA or should a different approach be adopted?

---- End E-mail.

Anyone got some views, comments etc. I am sure there are also other questions that arise from this non e-Health outcome from COAG.

Have a great ANZAC Day Weekend – Lest We Forget!

David.

Submissions on the Health Identifier Service Regulations are Now On-Line.

The submissions can be reviewed here:

http://www.health.gov.au/internet/main/publishing.nsf/Content/ehealth-submissions-regulations

The list of responders is well worth a browse and some of the issues raised are of interest.

What I see, in summary is:

1. A number of groups very concerned to be covered as Health Providers and in some cases this is going to be a little difficult to manage given the various qualification levels and the absence (as present of a registration entity.

Examples include the following:

Association of Soul Centred Psychotherapists

And

Psychonanlytic Psychotherapy Association of Australasia

And

Association of Counselling and Hypnotherapy Australia

2. The Office of the Privacy Commissioner has a few suggestions – In summary – From page 2:

Key recommendations

The Office of the Privacy Commissioner considers that the exposure draft regulations for the Healthcare Identifier Service enhances the privacy framework provided in the Healthcare Identifiers Bill 2010 (the Bill) to support the establishment of the Healthcare Identifier Service and the use of healthcare identifiers. The Office makes the following comments about the exposure draft regulations:

i. Regulation 10 could be strengthened by limiting the purposes for which healthcare identifiers can be collected. We consider that the collection of a healthcare identifier should be linked to the provision of healthcare to the individual healthcare recipient.

ii. The Office suggests that the title of Regulation 10 could be amended to reflect the content of the regulation.

iii. The development of guidelines to support proposed Regulation 10 is pleasing. The Office would appreciate the opportunity to be consulted in their development.

iv. We consider it is appropriate that Regulation 11 proposes a period of transition for active enforcement of penalty provisions. However, penalties should still be enforced in cases of systemic non-compliance.

v. The development of guidance about data security measures for entities handling healthcare identifiers would support the data security obligation in section 27 of the Bill.

The full submission can be found with this link.

http://www.health.gov.au/internet/main/publishing.nsf/Content/eHealthregs-008

3. The Australian Medical Association has now noticed just how much work is going to be involved in the red tape associated with the HI Service. They are concerned about the regulatory imposition and its costs – to say nothing of the scale of the penalties on offer!

See here:

http://www.health.gov.au/internet/main/publishing.nsf/Content/eHealthregs-003

One has to say their plea for some balance seems not unreasonable.

4. The Royal Australian College Of GP’s are also feeling they are a bit in the dark on a few matters.

4. Concluding comments

The College is supportive of UHIs, and looks forward to continuing discussions with the Department of Health and Ageing regarding UHIs prior to their progression and implementation.

In particular, the RACGP looks forward to receiving information providing clarity regarding:

• privacy safeguards and informed consent

• details of the communication strategy for the implementation process for both health providers and patients

• how implementation issues will be addressed, including the roll out of general practice software, installation, and funding

• application of HIs, including when to apply anonymous or pseudonymous IHIs

• how penalties will be implemented

• designation of a “responsible officer”.

Page 4 of Submission.

The direct link is here:

http://www.health.gov.au/internet/main/publishing.nsf/Content/eHealthregs-034/$FILE/034_The%20Royal%20Australian%20College%20of%20General%20Practitioners%20pt%202_09-04-10.pdf

5. The Medical Software Industry Association has also noticed an issue that will impact them.

From Page 3.

“Our submission describes a number of existing models of health IT provision are currently operating in the Australian health sector. We do not believe these healthcare information service vendors will be recognised as Healthcare Provider Organisations under the current draft Healthcare Identifier Regulations, although they will have requirements as Healthcare Provider Organisations in terms of accessing identifiers.

In all these cases, the health information service providers are not seeking to access a patient’s health identification number for use themselves, but rather, are seeking a means within the regulations of establishing a technical mechanism for their participating healthcare providers to use the patient identification number when appropriate consent is given. The technical mechanism that is most cost effective and technically robust is for the health information service provider to be issued a single healthcare provider organisation certificate themselves and use methods internal to the application to deliver HI information back to the requesting user.

The Medical Software Industry Association submits that while these information service providers may have a healthcare provider as a staff member and could perhaps apply for a healthcare provider organisation identifier under these arrangements, healthcare provision is not the core business of these parties. While the regulations do not stipulate that health care provision must be the core business in order to access the HI service, our reading of the regulations is that this is the spirit and intent of the wording. In any case this model would be unsatisfactory requiring IT service providers to engage healthcare providers simply for the purpose of obtaining an HI-O. It is also noted that processes to allow healthcare software vendors to continue to provide services without and HI-O certificate will be costly, cumbersome, and less secure.”

Another set of issues to be sorted out.

All in all there are a good few changes needing to be made in the regulations in the next little while and a fair bit of consultation required to ensure there is not an almost universal practitioner revolt due to the additional workload and red tape.

This could be a real fiasco if not thought through very carefully!

David.

Senator Boyce Comments on Recent Publicity Regarding Medicare System Reliability and Safety.

The following article appeared on Tuesday morning (while I was distracted by COAG).

Medicare glitch affects records

Karen Dearne

From: The Australian

April 20, 2010 12:00AM

A SOFTWARE glitch in Medicare's systems in February has caused a major safety alert, with the agency set to notify thousands of doctors that some patient records may have been incorrectly updated during a three-day period.

Medicare told The Australian yesterday that changes to its online patient verification system after maintenance on February 6 could have resulted in an adverse test result not being matched to the right person.

While the agency believes there is little risk to patient safety, it will contact affected medical practices so doctors can check their records and make corrections if necessary.

"About 1300 transactions to date (have been identified involving) software that automatically updates patient's first names linked to clinical systems," a Medicare spokesman said.

"This figure may increase as we finish contacting all vendors to determine how their software treats patient verification information. Care is needed to ensure retention of the patient's name as they are known to the practice -- the first name should not be overwritten without careful checking."

Lots more here:

http://www.theaustralian.com.au/australian-it/medicare-glitch-affects-records/story-e6frgakx-1225855706275

This has been followed up here:

Medicare slow to fix record bungle

MARK METHERELL

April 21, 2010

MEDICARE Australia has taken 10 weeks to alert 2700 medical practices of a bungle in the agency's computer system, which could have linked patients to the wrong diagnosis.

The problem has emerged at a sensitive time for the government, which is struggling to get agreement from doctors and others for regulations for the first steps of its national e-health scheme, the introduction of unique patient identifier numbers that are supposed to be introduced in July.

The potential for a mix-up between members of the same family arose after Medicare made minor software changes in early February. This had the unintended effect of switching the name of the patient receiving a service to another name on the Medicare card.

Medicare Australia said in a statement to the Herald yesterday that it was writing to 2700 medical practices to inform them and to provide details of their practice records where they may have been incorrectly updated.

Much more here:

http://www.smh.com.au/national/medicare-slow-to-fix-record-bungle-20100420-sru6.html

Clearly there has been a pretty major problem.

Now the Opposition has weighed in with the following release:

MEDICARE COMPUTER SYSTEM FAILURE PUT LIVES AT RISK: SENATOR SUE BOYCE

The health of tens of thousands of Australians may have been seriously compromised by a computer system glitch at Medicare which the government body had tried to keep secret for eight weeks, Liberal Senator Sue Boyce said today.

Senator Boyce said Medicare became aware on Monday, February 9 of a software problem which recorded patient details incorrectly without any indication of an error.

She said industry sources had told her that there had been more than 1,000,000 uses of the Online Patient Verification (OPV), Patient Verification (PVM) and Enterprise Patient Verification (EPV) during the period the glitch had affected the system.

"The Human Services Minister Chris Bowen has refused to apologise or even acknowledge this problem exists. His silence can only be seen as confirming that he is a prisoner of Medicare and not willing to stand up for patients against a bureaucracy more concerned with protecting itself than being honest and proactive in patients' interests."

"The results of this serious failure in the system have still not been completely checked and I understand from industry sources that almost 30,000 patient records are still affected as well as some 2,700 medical practices."

"However, despite the repeated pleadings by private software vendors in meetings with Medicare officers to go public, acknowledge the problem and alert health care providers, Medicare dithered and tried to cover it up for eight weeks before issuing a letter on April 1," Senator Boyce said.

"This letter must have been Medicare's private April Fool's Day joke because it tried to gloss over the problem by claiming that system functionality had been restored within three days of its being detected. What this conveniently ignored was that tens of thousands of patients' records had been corrupted," she said.

"Medicare has claimed that only 1,300 transactions have been identified so far as being affected by the glitch but there were more than 1,000,000 uses during the glitch affected period."

"I have been told that there are about a further 30,000 transactions already identified as needing to be checked . This is being freely acknowledged in the medical software industry and the medical profession. Originally, Medicare tried to assert that the problem only related to rebate claiming and that simply wasn't true as they have now been forced to admit. "

"I understand the fault meant that some pathology test results would not have made it back to the patient's GP or could have been attached to the medical history of a different family member. This glitch meant that only the first name appearing on a family Medicare card was recognised and all pathology results for others on the card were recorded for that person."

"Obviously, this could lead to misdiagnosis, no diagnosis, unneeded and possibly dangerous medication or no medication at all, depending on the order a person's name appeared on a family Medicare card."

Senator Boyce said to add insult to injury, Medicare had tried to infer in a statement published last Tuesday that the glitch was the fault of medical software providers.

"This is a blatant lie as all software that accesses Medicare has to have a NOI – a Notice of Integration – which means Medicare itself has tested the software and found it meets their standards. To try and suggest now that the glitch was the fault of vendors' software is an own goal. If the vendors' software was at fault, then Medicare is actually saying their own quality assurance processis useless," Senator Boyce said.

Senator Boyce said some software providers to Medicare had held several meetings with senior Medicare officers through February and March pleading with them to come clean about the on-going problem.

"It seems that the statement Medicare issued last Tuesday is the payback for these software providers who dared to question them," Senator Boyce said.

"The medical software industry and the medical profession itself remain deeply concerned not just about the ongoing problem but Medicare's attempts to sweep it under the carpet. This does not bode well for the future when Medicare has an even more central and enhanced role in the national e-health network," she said.

"All healthcare providers including medicos are worried about the possible effects of this ongoing problem particularly the inadvertent harming of patients."

April 21, 2010

It is really good to see the amount of research that Senator Boyce and her office have done - clearly speaking to the MSIA and so on - to form their views.

Given the way COAG has just ignored e-Health it is great to see the Opposition making sure there is some accountability in all this.

I hope NEHTA is the next target, as there are a lot of issues there that could really do with some ‘sunlight’

David.

This is Going to Be a Very Exciting Journey and Risks Very Considerable Difficulties.

Well Mr Rudd and Ms Roxon have almost got their Health Reform Package through. Now to see how they go implementing it!

The first thing to be said about the communiqué is that it is amazing how many times the phrase – “COAG agreed, with the exception of Western Australia,” gets used!

The second thing that is really of some considerable concern is the number of times it is assumed that information will be available to guide various aspects of implementation – and how there has been no investment to ensure that information will be available. Any investment in e-Health has been put off into the (distant) future and it is now not clear who will pay for what.

With Mr Rudd funding 60% of public hospitals – does that include Health IT and so on. He has been saying he is picking up all new capital expenses so I wonder what that means for HealthSMART and NEHTA?

For the record here is what was said about e-Health.

“E-Health

COAG noted the importance of continuing to work towards a National Individual Electronic Health Record system and agreed to prioritise discussions over the coming months to move towards the implementation phase.”

Page 12 of Communiqué.

Sadly we still have rubbish about IEHRs and so on and no plan for implementation of the National E-Health Strategy. Fortunately mention of the Personally Controlled EHRs seems to have been weeded out.

The third thing that really caught my eye was this from the Network Agreement.

Responsibilities of the States

A1. States will be responsible for:

a. being the system manager and single purchaser of public hospital services, in order to ensure clear responsibility for day-to-day hospital system operation to deliver strong performance and patient outcomes;

b. system-wide public hospital service planning and policy, including arrangements for providing highly specialised services and adjusting services between LHNs to meet changes in demand;

c. system-wide public hospital capital planning and management, and capital planning and project management for hospital capital projects;

d. in most cases, ownership of existing and new public hospital capital and assets, unless decided otherwise by the State; and

e. managing LHN performance.

A2. States will be responsible for purchasing services from LHNs under a LHN Service Agreement, which will include:

a. the number and broad mix of services to be provided by the LHN;

b. the quality and service standards that apply to services delivered by the LHN, including the Performance and Accountability Framework;

c. the level of funding to be provided to the LHN under the LHN Service Agreement, through ABF and block funding; and

d. the teaching and research functions to be undertaken at the LHN level.

- Page 16.

To the uninformed eye this looks remarkably like the States retain control – to mess up – the public hospitals but have a bigger bucket of money to do it with.

Fourth, it is clear there are a lot of people at the ‘coal face’ who are deeply sceptical as to how this will all work – especially in the hoped for integration with primary, aged, preventive and mental health services. Most seem to think the ‘blame game’ is still on for one and all!

This link provides a very useful transcript and discussion.

http://www.abc.net.au/worldtoday/content/2010/s2878916.htm

Play MP3 of Panel picks apart Prime Minister's plan ( minutes)

• (Presenter) Eleanor Hall

12:14:00 21/04/2010

Panel picks apart Prime Minister's plan

The World Today invites John Dwyer, Professor of Medicine at the University of NSW; Prue Power, head of the Australian Health Care and Hospitals Association; Dr Sally McCarthy, president of the Australasian College of Emergency Medicine; and Professor Ian Hickie, from the Brain and Mind Research Institute at Sydney University, to discuss the merits, or otherwise, of the Prime Minister's plan.

Last we do have the issue of implementation risk. The Australian Health System has a very large number of moving parts and I suspect all sorts of ‘unintended consequences’ will emerge from all this.

Well pretty much enough on all this – we shall wait, watch and despair at the incoherent approach to Health Information Technology being adopted by this Government.

Those who suggest this was a lot about politics and a little about health may be right.

A useful summary of the reactions is found here:

http://www.theaustralian.com.au/politics/doctors-divide-over-status-quo-in-pools/story-e6frgczf-1225856143068

Doctors divide over status quo in pools

• Adam Cresswell and Lanai Vasek
• From: The Australian
• April 21, 2010 12:00AM

THE price of health reform -- allowing states to play a continuing key role in the running of hospitals -- is a disappointment for many doctors and experts are concerned it may create a business as usual mentality.

Handing states the role of funding the new local hospital networks -- instead of funding them directly from Canberra -- emerged as one of the concessions that persuaded rebel states NSW and Victoria to sign on.

----

As a near final comment I found these remarks really offensive and ill considered.

http://news.smh.com.au/breaking-news-national/deal-adds-cash-but-no-big-reform-doctor-20100421-ssfs.html

Deal adds cash but no big reform: doctor

April 21, 2010 - 9:34AM

.....

Prof Dwyer, chair of the Australian Healthcare Reform Alliance, believes the problems with the hospitals system won’t change under an arrangement where the Commonwealth becomes the dominant funder.

The bickering that occurred during this week’s meeting of the Council of Australian Governments was just a preview of what was to come given the states and territories and the commonwealth were still sharing responsibility.

“It’s not going to change the inefficiencies, the duplications,” Prof Dwyer said.

“We’re still going to have nine departments of health for 22 million people, we’ve still got all the cross-border area problems because we don’t have a single funder.”

The federal government and state counterparts lost an opportunity to implement significant change, such as integrating primary, community and hospitals care into one, Prof Dwyer said.

“We could live with the fact that it might take us three or four years to change this and that, but that journey’s not laid out on the table.”

Prime Minister Kevin Rudd dismissed the criticism, saying he was just one of thousands of doctors across the country who had their own ideas about how best to tackle health reform.

-----

Obviously a man suffering from a very large dose of arrogance and rudeness. John Dwyer and Ian Hickie have forgotten more about health services than this PM will ever know.

I think this from Adam Cresswell best summarises my view.

http://www.theaustralian.com.au/news/health-science/health-deal-trade-offs-limit-the-utility-of-pact/story-e6frg8y6-1225856346930

Health deal trade-offs limit the utility of pact

• COMMENT: Adam Cresswell
• From: The Australian
• April 21, 2010 11:45AM

KEVIN Rudd's original plan envisaged the states still having "some skin in the game", namely a financial incentive to make sure hospitals were efficient and not wasting cash.

The trouble is, the compromise worked out yesterday gives the states not just skin, but arms, legs and hands as well. And many fear they will be using those limbs to meddle in the remodelled arrangements far more than originally planned.

.....

The consensus appears to be that it's all a lost opportunity for the Rudd reforms, which some feel may now never accomplish their full potential.

What went wrong? For one thing, Rudd and his Health Minister, Nicola Roxon, almost certainly spent too long -- seven months -- jetting around more than 100 of the nation's hospitals to consult on last year's Bennett report findings, but then left themselves just seven weeks to sell their response to the report.

For another, the proposed reforms were simply not sold very well.

As many have pointed out, there was undue emphasis on hospitals at the expense of primary care -- which could help keep patients out of hospitals in the first place -- and the government's response deteriorated into a series of ever less coherent announcements more designed to buying off doubters than contributing to systemic reform.

The response came to resemble everything that the two-year reform process was supposed not to be: rushed, politicised and ad-hoc. The government's reform credentials will hinge on its ability to turn that perception around.

-----

David.

COAG Outcomes Posted April 21, 2010

Here is the direct link to the communique.

http://www.coag.gov.au/coag_meeting_outcomes/2010-04-19/docs/Communique_20_April_2010.pdf

If you want the text of the NHHN Agreement it is here:

http://www.coag.gov.au/coag_meeting_outcomes/2010-04-19/docs/NHHN_Agreement.rtf

Total comments on e-Health.

E-Health

COAG noted the importance of continuing to work towards a National Individual Electronic Health Record system and agreed to prioritise discussions over the coming months to move towards the implementation phase.

Comments later after I have digested.

David.

COAG Update 10pm April 29, 2010

Just checked - no e-Health News as of now.

Seems NEHTA is the bridesmaid and will never be a bride at this rate. COAG seems to have flicked their plans down the hill again - rightly in my view - for attempting to get funding for something no one outside the inner NEHTA and DoHA circle has ever seen!

Maybe we might need to have a serious rethink as to objectives, priorities etc in the face of a re-designed health system?

I would expect - but I am sure we will not see - a plan from NEHTA (and DoHA) about how the e-Health needs of the new health system and its various sectors will be addressed over the next few years.

The COAG communique is still not on the website as of 10pm. Bit of a worry I reckon.

Don't hold your breath.

David.

The Spin About Success is Really On a Roll. This is Really Very Sad in My View!

What a policy failure!

Rudd strikes deal with Labor leaders

April 20, 2010 - 5:28PM

Prime Minister Kevin Rudd has reached agreement with Labor state and territory leaders over his planned health reforms.

But Western Australia won't be a party to the deal hammered out during intense negotiations in Canberra.

Mr Rudd won over Kristina Keneally earlier today following one-on-one discussions with the NSW Premier.

Later discussions with John Brumby convinced the Victoria Premier to sign up to a plan under which the Commonwealth will retain about a third of the states' and territories' GST revenues.

The federal government will use that money to help it finance its role as the dominant funder of the nation's public hospitals.

Sources say Mr Rudd has had a victory on his GST clawback, but the funds will be directed into a pool, which will distribute funding to local hospital networks.

Tasmanian Premier David Bartlett put his signature to a new intergovernmental health agreement before rushing off to catch a plane home.

More here:

http://www.smh.com.au/national/rudd-strikes-deal-with-labor-leaders-20100420-sra1.html

With the totality of the funds going to these tiny networks via a pool controlled by the States – how is that going to be manageable and how will the Commonwealth make sure all this performs.

As for integration of hospital, aged and primary and community care – who knows?

As for e-Health – well you know – ignored again!

For me this is all about politics and not about a better health system.

David.

AusHealthIT Man Poll Number 16 – Results - 20 April, 2010.

The question was:

Should a National Health Reform Plan be Agreed at COAG without a Detailed E-Health Plan?

No Way

- 21 (65%)

Probably Not

- 7 (21%)

Maybe

- 0 (0%)

Seems OK to Me

- 4 (12%)

Votes : 32

Comment:

Well that was utterly clear – not that the Government took any notice.

I wonder what will happen next? Nothing good I fear.

Thanks again to all who voted.

David.