Quote Of The Year

Timeless Quotes - Sadly The Late Paul Shetler - "Its not Your Health Record it's a Government Record Of Your Health Information"

or

H. L. Mencken - "For every complex problem there is an answer that is clear, simple, and wrong."

Wednesday, July 08, 2015

Here Is Another Source Of Information Error and Lack Of Trustworthiness In The PCEHR.

This appeared a few days ago.

Vaccine records need GP attention: audit

Michael Woodhead0 comments
An audit of the national immunisation register has exposed a number of holes in the system including tardy notification by GPs, poor communication and practice software incompatibilities
The audit of the Australian Childhood Immunisation Register (ACIR) that covers more than two million children up to the age of seven was carried out by the Australian National Audit Office.
Overall the audit concluded that childhood immunisation data was generally well managed by the department, with accuracy rates in excess of 98%.
However it revealed a number of concerning areas that the authors said needed improvement.  
It found one-quarter of immunisation notifications were submitted late by GPs, putting families at risk of having their childcare benefits cancelled because immunisations are deemed overdue after a cut-off of 63 days,
The audit also found simple data entry errors by practice staff such as a wrong date of birth or a misspelled name could lead to duplication or misrecording of a child's immunisation status.
It noted that the Department of Human Services had previously provided field officers to give support and education to general practices in submitting immunisation data correctly.
But these services had been reduced and their future was uncertain following the abolition of Medicare Locals.
Another weakness of the ACIR system was that it assumed GPs and parents would check immunisation statements to verify that the data they had submitted had been incorporated into the records. 
However, this expectation was not being communicated to GPs, the audit found.
"Human Services' expectations in respect to maintaining the accuracy of the register are not clearly and consistently communicated to parents and providers, and the department should include a statement to this effect in relevant communication materials, including the Immunisation History Statement sent to parents and the monthly payment summaries sent to providers," it recommended.
More here:
The Departments of Human Services and Health really are letting us all down here - especially as people can low loose payments from Centrelink if the information held by the Departments is inaccurate.
These Departments are meant to manage YOUR information properly and ensure it is accurate - which means having decent information governance and systems which are properly monitored and maintained.
Before you give them any more information via the PCEHR you might want to see is they can actually manage something as simple as an immunisation register. Seems they can’t!
David.

Tuesday, July 07, 2015

Is Seems Telstra Is About To Make A Big Splash in Telemedicine. I Wonder How Heavily It Will Be Used?

There was a great deal of coverage after the Telstra Press Release.

Telstra Health’s ReadyCare new option to connect patients to doctors

Telstra Health today launched ReadyCare, its GP telemedicine service that gives Australians the choice to connect with a doctor using phone or video and receive advice, treatment, diagnosis and prescriptions.
The service will make accessing a doctor easier, especially at times when people may not be able to visit their regular GP such as after hours, on weekends or while travelling. It can be accessed by calling 1800 READYCARE (1800 732392) or through the ReadyCare app.
Shane Solomon, Managing Director of Telstra Health, said that ReadyCare has employed registered Australian doctors who will operate the service 24 hours a day. Patients will first speak to a telemedicine assistant to determine if the call is suitable for a telemedicine consultation and a GP will then call them back at a time that suits the patient. The service operates from a purpose built telemedicine centre in the Sydney suburb of Alexandria.
“We’ve seen what the digital revolution has meant for other sectors and we believe that healthcare in Australia will benefit from eHealth to better serve all Australians,” Mr Solomon said.
“This will provide choice and convenience for people to access a GP regardless of their location or the time of day, particularly in circumstances when they find it hard to access a face to face doctor. Patients can talk with a GP using phone or video, upload images of their condition and receive comprehensive care.
“ReadyCare is based on technology and processes used by Medgate, the leading telemedicine provider in Europe, who currently conduct more than 4,300 telemedicine consultations daily. The evidence-based clinical guidelines have been refined to meet Australian conditions, with input from a Clinical Advisory Panel and delivered by qualified, Australian based doctors,” Mr Solomon said.
Gianin Zogg, who leads Medgate’s international business and has been involved with Medgate since its inception 15 years ago, has been appointed as Chief Executive Officer and Dr Amandeep Hansra has been appointed as the Chief Medical Officer. The service will be advised by a Clinical Advisory Panel of:
  • Dr Chris Mitchell AM, past President of the Royal Australian College of General Practitioners
  • Associate Professor Bruce Chater OAM, past President of the Australian College of Rural and Remote Medicine
  • Associate Professor Sally McCarthy, past President of the Australasian College for Emergency Medicine
Mr Solomon emphasised that while ReadyCare will employ the doctors at the time of launch, the long term aim is for ReadyCare to be available for any GP to use with their regular patients.
“We’re introducing and operating ReadyCare in the first instance to demonstrate how telemedicine services can be provided safely and address issues such as timely access to care, but ultimately we want it to be a platform that will enable GPs to provide convenient and accessible telemedicine services for their own patients.
“ReadyCare is intended to be a complementary service, not a replacement for a regular face to face GP appointment. Telemedicine has proven very effective in delivering quality care for patients in other parts of the world, especially the USA and Europe and we are confident Australians will embrace the service,” Mr Solomon said.
Telstra Health also announced that Cover-More Group, Australia’s leading specialist travel insurance and medical assistance provider, had signed on as a foundation customer of ReadyCare’s telemedicine service.
The release with more details is found here:
Typical press coverage was found here:

Telstra's GP telemedicine service, ReadyCare, is up and running

Simon Thomsen Jul 2, 2015, 11:10 AM
and here:

Telstra launches its telemedicine service

ReadyCare opens for consultations
and here:

24/7 televideo e-health: the doctor will see you now … via video

Mitchell Bingemann

It seems the service plans to charge between $70 and $80 per consultation so it will be interesting how heavily used the service is and just what level of patient satisfaction is achieved.
We can track how it is going by seeing how Telstra Health’s revenue rises over time I guess. Will be interesting.
Will also be interesting to see how the medico-legal issues etc. have been resolved.
(Disclosure - I have a few Telstra Shares in my super fund)
David.

Monday, July 06, 2015

Weekly Australian Health IT Links – 6th July, 2015.

Here are a few I have come across the last week or so.
Note: Each link is followed by a title and a few paragraphs. For the full article click on the link above title of the article. Note also that full access to some links may require site registration or subscription payment.

General Comment

What a busy week with Telstra off and rolling, education for the new PCEHR tendered and the new Royal Adelaide Hospital seemingly in more Health IT trouble.
Enjoy the read!
-----

Govt readies e-health record push to boost adoption



Training drive slated for 2016.

The Department of Health will renew efforts to address under-utilisation of electronic health records by the clinical community, with a training and promotion campaign due to kick off in January 2016.
The federal government’s $1 billion e-health scheme - originally dubbed the personally controlled electronic health record (PCEHR) but since rebadged myHealth Record - has struggled against poor adoption rates since the system went live in 2012.
Ahead of the May 2015 budget, Health Minister Susan Ley said the government would make the electronic health records ‘opt-out’ - giving all Australians an account by default.
-----

New service provides consultation with your doctor by telephone or video

Telstra Health has launched a new GP telemedicine service – ReadyCare – that facilitates access to a doctor using phone or video to receive advice, treatment, diagnosis and prescriptions.
Registered doctors have been employed by the service which will operate 24-hours a day from a purpose built telemedicine centre in the Sydney suburb of Alexandria. The service can be accessed by calling 1800 READYCARE (1800732392) or through the ReadyCare app.
Shane Solomon, Managing Director of Telstra Health, said patients calling ReadyCare will first speak to a telemedicine assistant to determine if the call is suitable for a telemedicine consultation and a GP will then call them back at a time that suits the patient.
-----

Telstra's GP telemedicine service, ReadyCare, is up and running

Simon Thomsen Jul 2, 2015, 11:10 AM
House calls by a doctor have a whole new meaning with Telstra launching ReadyCare, its telemedicine service, today.
The telco’s health division has built the digital project, including a purpose-built centre in Sydney’s Alexandria. It lets people speak to a doctor via phone or video for advice, treatment, diagnosis and prescriptions. Patients are screened, first up, to see if they’re suitable for an e-health consultation.
Telstra Health managing director Shane Solomon said the 24/7 service was the next logical step in Australian health care in the digital era. There’s even a smartphone app, as well as a toll-free number to call.
-----

Telstra launches its telemedicine service

ReadyCare opens for consultations
Telstra Health, the telco's healthcare focussed business, has officially launched its ReadyCare service.
ReadyCare offers 24/7 remote consultations with GPs through a hotline (1800 READYCARE) or an app.
An Android app will be in the Play store from tomorrow and an iOS app is expected to be available within the next two to three weeks.
ReadyCare is a product of Telstra Health's partnership with Swiss telemedicine company Medgate.
"ReadyCare is based on technology and processes used by Medgate, the leading telemedicine provider in Europe, who currently conduct more than 4300 telemedicine consultations daily," Telstra Health managing director Shane Solomon said.
-----

Medical privacy 'at risk'

29th Jun 2015
A NATIONAL privacy rights group has criticised plans to transition the PCEHR to an opt-out system, warning the “minimal value and benefits” of a PCEHR do not match the privacy risk of establishing a repository of every Australian’s identity and health data.
The Australian Privacy Foundation warns the data repository won’t just be of high value to hackers. 
“The identity data will be seen as very useful to the government, especially when cross-matched against internet and tele­communications metadata and other government databases,” it says.
-----

The other data retention: Concerns over opt-out eHealth model

Australian Privacy Foundation says opt-out model for eHealth record not justified
The government's move to change the current national eHealth record rollout to an opt-out model has raised concerns among privacy advocates.
A 2013 review into the Personally Controlled Electronic Health Record (PCEHR) recommended changing from opt-in to opt-out in order to boost uptake to help the system to reach critical mass.
The government's response to the review included moving to rename the PCEHR to 'My Health Record' and trialling an opt-out approach.
"Doctors have indicated they’re much more likely to use the system if all their patients have a record," health minister Sussan Ley said earlier this year.
-----

Indigenous Eye Health On Track and Online

on July 1, 2015 at 12:10 pm
In a report published by the Medical Journal of Australia, support for Indigenous eye care is improving according to 42 recommendations made in a roadmap aiming to close the gap in health services. University of Melbourne researchers Dr Marian Abouzeid, Mitchell Anjou and Professor Hugh Taylor said that progress has been made to increase services, improve efficiencies and support better Indigenous patient engagement with the eye care system.
Key objectives of the roadmap include:
  • The increase of accessibility and uptake of eye care services by Indigenous Australians
  • Improvement of coordination between eye care providers, primary care and hospital services
  • Improvement of awareness of eye health among patients and clinicians; and
  • Ensuring culturally appropriate health services.
-----

New Royal Adelaide Hospital faces a dud IT system, surgeons say

  • July 02, 2015 9:29PM
  • MEDICAL REPORTER BRAD CROUCH
THE troubled $422 million IT system that is meant to run the new Royal Adelaide Hospital is “disastrous”, according to surgeons who have rejected State Government assurances that all is well.
The usually conservative Royal Australasian College of Surgeons has warned it could not guarantee patient safety under the planned system because of problems that include doctors being prevented from prescribing essential medicines.
SA Health’s planned Enterprise Patient Administration System (EPAS) was supposed to be introduced to hospitals across the state but is now in just three, including the Repatriation General Hospital – where medical staff have officially complained to Health Minister Jack Snelling because it is compromising patient safety.
The new RAH has been designed to operate solely with EPAS and there is no space for a paper-based records system.
-----

eHealth delays threaten new Royal Adelaide Hospital

Friday, July 3, 2015 - 11:02
Promised as a flagbearer for the brave new world of eHealth when it opens in April 2016, the $1.85 billion new Royal Adelaide Hospital (nRAH) will instead have to cope with a “hybrid” environment including paper records and workflow due to delays in a decade long program to implement a state-wide electronic health record.
Promoted as Australia's most advanced hospital, the nRAH is also facing supply chain issues due to SA Health’s a failure to complete a long running rollout of Oracle, initially commenced in 2010.
A report from the South Australian Auditor General handed to the Parliament this week says a 10 year, S214 million program commenced in 2007 to deliver a state-wide Enterprise Patient Administration System (EPAS) had “ambitious timeframes and an under estimation and lack of detailed understanding of the effort required. In particular, the underestimation of effort required to implement EPAS at a major hospital site.
-----
Health | Fri Jun 26, 2015 11:48am EDT

Online tools can help manage pain

By Lisa Rapaport
 (Reuters Health) - People with chronic pain may be able to use online tools to manage their symptoms, lessening the need for frequent doctor visits, an Australian study suggests.
Researchers tested a series of web-based pain management tutorials on a group of adults who had been suffering symptoms for more than six months. Regardless of how much contact the patients had with clinicians, they all experienced significant reductions in disability, anxiety and average pain levels at the end of the eight week experiment as well as three months down the line.
“While face-to-face pain management programs are important, many adults with chronic pain can benefit from programs delivered via the internet, and many of them do not need a lot of contact with a clinician in order to benefit,” lead study author Blake Dear, a psychology researcher at Macquarie University in New South Wales, said by email.
-----

Melbourne doctors get behind a new health website

Date June 29, 2015 - 12:45PM
A new health website backed by Melbourne doctors was launched at the weekend.
Doctors are usually very wary when patients turn to "Dr Google" to look up symptoms or self-diagnose an illness.  
But a group of Melbourne health professionals are behind a new regulated website designed to give accurate medical information.
Launched on the weekend, HealthAnd.com touts itself as an e-health site to store health information and answer frequently asked medical questions. 
-----

Vaccine records need GP attention: audit

Michael Woodhead | June 29, 2015 |
An audit of the national immunisation register has exposed a number of holes in the system including tardy notification by GPs, poor communication and practice software incompatibilities
The audit of the Australian Childhood Immunisation Register (ACIR) that covers more than two million children up to the age of seven was carried out by the Australian National Audit Office.
Overall the audit concluded that childhood immunisation data was generally well managed by the department, with accuracy rates in excess of 98%.
However it revealed a number of concerning areas that the authors said needed improvement.  
-----

Tech Talk: 'Smart skin’ UV detector

Serkan Ozturk | July 1, 2015 |
In this week’s Tech Talk, we take a look at 'smart skin' technology, new travel medicine software for GPs and plans for the expansion of eHealth in rural NSW.
'Smart skin’ UV detector
Dubbed 'smart skin’ technology, Australian researchers are confident that a new material containing fine layers of zinc oxide will soon alert wearers to harmful levels of pollution and UV radiation.
Developed by a team at RMIT, the technology involves users wearing stretchy electronic sensors that have the ability to sense gases such as hydrogen and nitrogen dioxide, as well as UV exposure.
Researcher Dr Madhu Bhaskaran (pictured, with the material) says the technology — to be integrated with smart watches and other digital devices — is expected to be available to the public in the next five years. “The UV sensors can play a vital role in preventing skin cancer by warning people when the UV index is high and UV exposure has exceeded a safe level,” Dr Bhaskaran says.
-----

Scanning the brain's magnetic fields offers hope for epilepsy patients

Date June 29, 2015 - 6:30PM

Bridie Smith

Science Editor, The Age

Stewart Duguid used to have an epileptic seizure every fortnight. He never knew when they  would strike,  and they proved impossible to control with medication.
"I had the tonic clonic seizures, the ones where you fall to the ground and shake," the 26-year-old said. "I'd wake up exhausted and need to get my breath back."
However, for the past year he has been living seizure-free after being among the first Australians to have a MEG machine scan his brain's magnetic fields.
Using the machine, doctors were able to pinpoint where the abnormal activity was coming from before surgeons operated last May and removed a section of brain from his frontal cortex.
-----

SA's new regional primary health network starts work

July 1, 2015
The new body managing primary health services across regional South Australia begins operations today.
Last year, the Federal Government announced it was slashing funds to the nation's 61 Medicare Locals introduced by Labor, replacing them with 'Health Networks'.
The networks will focus on national priorities of chronic disease management, mental health, aged care, e-health and ensuring a sustainable workforce.
-----

CEOs reveal their biggest mistakes

  • June 28, 2015 12:58PM
EVERYONE makes mistakes.
Chances are, your boss has made more than you. Here, six Aussie chief executives reveal some of their early blunders, and importantly, what they learned in the process.
Phil Offer, CEO, Medical Director
“Before moving into e-health I worked in telecommunications for more than 16 years. The great thing about the industry’s pace is you need to make calls on issues all the time — which is code for, things don’t always go to plan.
In the early noughties, I reviewed pricing for the lead handsets that the acquisition teams were recommending. Back then, ‘big data’ and ‘algorithms’ weren’t even buzzwords, so demand planning was more art than science.
The team decided to capitalise on a new Nokia handset and drop it to a lower price to stimulate sales. We thought it would go well and modelled the sales upside and short-term impact from the handset subsidy.
-----

NBN satellite to give bush a cleaner bill of health

The NBN satellite service promises to deliver a boon for rural Australia with results of one telehealth pilot program highlighting its enormous potential to provide diagnostic health services to those in remote locations.
A trial by a team of CSIRO researchers has used the interim NBN satellite services to successfully deliver a solution that ­connects specialists to patients in remote areas, who generally have little or no access to eye screenings.
The trial was carried via the ­installation of satellite dishes in eight community health centres — four in the Torres Strait Islands and another four in southern Western Australia. The retinal images and health data was uploaded over satellite broadband on to the electronic health records of the patients and sent to specialists for consultation.
-----

Warning: digital challenges ahead

There were a few interesting tech news facts this week. I thought this one was pretty crazy: a Dutch campaign group used a drone to deliver abortion pills to Polish women, in an attempt to highlight Poland’s restrictive laws against pregnancy terminations.
There was scary news too: a private health insurer encouraged its members to use a Facebook-owned exercise app to qualify for free cinema tickets. Not surprisingly, Facebook was entitled to disclose all information shared via the app, including personal identity information, to its affiliates.
But there was also this: Telstra has launched its ReadyCare telehealth service. For those willing to pay $76, a doctor on the other end of the phone or video link is ready to care for you. No need to visit a GP or emergency department.
-----

NEHTA reduces time and effort for vendors connecting to the PCEHR

Created on Wednesday, 01 July 2015
The National E-Health Transition Authority (NEHTA) has today published revised guidelines for software vendors that will reduce the time and effort of integrating their products with the Personally Controlled E-Health Records (PCEHR).
The Conformance, Compliance and Accreditation (CCA) Governance Group and NEHTA have listened to and acted on feedback from the health software industry and state and territory governments about the need to make this process quicker and more accessible.
However, vendors have previously undergone a ‘Conformance, Compliance and Accreditation (CCA) process’ to obtain approval to connect to the PCEHR which involved NEHTA observing vendor self-assessments. Under the new guidelines, from 1 July 2015, NEHTA will no longer observe vendor self-assessments. Instead, vendors will ‘self-declare’ conformance to PCEHR specifications directly to the Department of Health as PCEHR System Operator under a new ‘Conformance, Compliance and Declaration (CCD) process’.
-----

Kiwi tech receives clean bill of health as Orion wins big in UK

“This award is welcome recognition of the vital health benefits Orion Health is helping provide across the United Kingdom."
New Zealand-based technology firm Orion Health has won the 2015 HealthInvestor award for Technology Provider of the Year for establishing partnerships that deliver better healthcare services.
Presenting the award at a gala evening with over 1300 health sector leaders in London earlier this month, judges claimed Orion Health stood out for having a “big impact in providing technology to health services where it most mattered across numerous major UK health projects.”
The judges cited Orion Health for its role in “innovative and ground-breaking partnerships” helping a “highly vulnerable, formerly ill-served group of patients, generating great results,” and an “excellent example of clinical business partnership in patients’ interest.”
-----

Turnbull says Libs vindicated as 5 pay for high-speed broadband

Annabel Hepworth

Only five consumers have been willing to pay for internet speeds exceeding 100 megabits per second on the National Broadband Network, undermining Labor’s rhetoric about the demands for super-fast broadband.
The Australian can reveal that while the NBN has been rolled out to more than one million homes and businesses, just five consumers are on the package offering 250Mbps downloads and none has taken up a 500Mbps package.
The Australian has also been told that while 34 accounts are on the “gigabit nation” 1000Mbps downloads option, these are not genuine services provided to an end user as a one-gigabit service because they were either ordered in error or are being used for testing by service providers.
-----
  • Jul 3 2015 at 2:49 PM

Coalition policy shift creates NBN Co mess

by David Havyatt
In opposition, Malcolm Turnbull framed the NBN rollout as "in crisis," despite all NBN Co had achieved up to September 2013. As Communications Minister he has framed the NBN as a "mess" that needs to be "fixed," a frame that has been accepted by most commentators.
Eighteen months after NBN Co provided the Minister with its Strategic Review, he is persevering with that message while in reality the "mess" is a direct result of policy shift by the Coalition Government.
Mr Turnbull's pre-election framing reached a high point with the assertion that the "real cost" of Labor's NBN plan would be $94 billion, a figure splashed across the front page of the Daily Telegraph with no alternative analysis. The Coalition policy committed to all Australians having a 25Mbps service by 2016.
The Coalition's confidence in their ability to change the NBN was repeated by the Prime Minister in his Letter to Australians on election night, saying: "I want our NBN rolled out within three years and Malcolm Turnbull is the right person to make this happen."
-----

Mark Zuckerberg thinks telepathy is the future, here's how it could actually work

Date July 2, 2015 - 10:48AM

Caitlin Dewey

Internet satellites, virtual reality, even real working AI: It all pales in comparison to the future that Facebook chief executive Mark Zuckerberg has in mind. In a Q&A session with site users on Tuesday, the 31-year-old said he envisions a world where people — presumably Facebook users — don't need these types of communication intermediaries. Instead, they'll communicate brain-to-brain, using telepathy.
"One day, I believe we'll be able to send full rich thoughts to each other directly using technology," Zuckerberg wrote in response to a question about what's next for Facebook. "You'll just be able to think of something and your friends will immediately be able to experience it too."
But hold up: Is that even possible? And is that something anyone actually wants? TL;DR: Theoretically, yes; and, er — maybe not.
-----
Enjoy!
David.

Sunday, July 05, 2015

Some Intelligent And Hardly Complimentary Commentary On The Government Plans For The PCEHR. There Are Some Serious Issues Raised Here.

DoH asked for submissions on their plans for the Legislation around a modified PCEHR
Here is the link:
They closed on June 24, 2015.
In response, first we had some useful commentary from the RACGP.
You can find their submission here:

RACGP Submission to the Department of Health on the Electronic Health Records and Healthcare Identifiers Legislation Discussion Paper

24 June 2015
The RACGP welcomes the commitment made by the Government in its 2015-16 budget to strengthen the national e-health system and support the continued development of the PCEHR. There are well identified issues with the current PCEHR model that require meaningful engagement between the Federal Government and the healthcare sector in order for these issues to be addressed effectively and for the PCEHR to be adopted. It is our view that the ongoing work program should focus on:
  • the core clinical documents relevant to general practice (Shared Health Summary and Event Summary)
  • medicines reconciliation, and
  • point-to-point communication (interoperable Secure Message Delivery).
These are the core clinical value propositions for GPs and other clinicians and provide the platform for continuing engagement with the clinical community.

Downloads

RACGP Submission To The Department Of Health On The Electronic Health Records And Healthcare Identifiers Legislation Discussion Paper (pdf 423KB)

Here is the direct link:
I was quite surprised to read the submission and see just how many issues the RACGP identified. The make it very clear there is a massive mountain of work to do to get their support.
There is some coverage of this submission and one from the APF found here:

The other data retention: Concerns over opt-out eHealth model

Australian Privacy Foundation says opt-out model for eHealth record not justified
The government's move to change the current national eHealth record rollout to an opt-out model has raised concerns among privacy advocates.
A 2013 review into the Personally Controlled Electronic Health Record (PCEHR) recommended changing from opt-in to opt-out in order to boost uptake to help the system to reach critical mass.
The government's response to the review included moving to rename the PCEHR to 'My Health Record' and trialling an opt-out approach.
"Doctors have indicated they’re much more likely to use the system if all their patients have a record," health minister Sussan Ley said earlier this year.
"We also need full coverage if we’re to cut down on inefficiencies created by not having one seamless records system, such as double ups with testing, prescriptions and other procedures."
However in a submission (PDF) to a Department of Health consultation, which closed late last month, the Australian Privacy Foundation (APF) argued that moving to an opt-out model is not justified.
The shift will only increase the risks to privacy that already exist from having "a high value repository of every Australian’s identity and health data".
"With respect to the proposed move to opt-out, we believe that there is a strong possibility that there will be a realisation amongst the population at large that the PCEHR is actually a thinly disguised national identity number attached to some health information, none of which can be relied upon because there is no way to medico-legally trust the information contained," the APF argued in its submission.
"[T]he identity data will be seen as very useful to the government, especially when cross-matched against internet and telecommunications metadata and other government databases," the organisation argued.
The government should either decommission the system or completely re-architect it "such that it is able to support major changes to existing health care work practices and is much better and more closely integrated with existing health record systems".
The shift to an opt-out model will have consequences for the risk profile of the eHealth program, the APF said.
Lots more here:
There is also coverage here:
http://www.medicalobserver.com.au/news/medical-privacy-at-risk

The Australian Privacy Foundation (APF) Submission is found here:
Here is the Exec Summary.

Summary and Conclusions

The Australian Privacy Foundation has  a number of very serious concerns with the PCEHR, the  proposed changes to the system and its enabling legislation.
These can be summarised as follows:
1. The value of the PCEHR, as only one eHealth system in Australia, has not been  demonstrated. The PCEHR has been implemented such that it replicates current health care  practices and therefore offers limited functionality. The opportunity to enable better and  more effective and efficient work processes has been missed;
2. The documentation available on the websites of NEHTA and the Health Department is old, inconsistent, incomplete and does not adequately describe the fundamental drivers and requirements of eHealth care or the way in which these have been architected and designed
into the system; and
3. The risks to privacy of a high value repository of every Australian’s identity and health data are not matched by the minimal value and benefits inherent in the PCEHR. Moving to an opt-out model is not justified and will only increase that risk.
A major factor is the poor legislative protection afforded to health information in Australia which, in our opinion, has led to a lack of trust that the risks are, or will be, adequately managed. With respect to the proposed move to opt-out, we believe that there is a strong possibility that  there will be a realisation amongst the population at large that the PCEHR is actually a thinly disguised national identity number attached to some health information, none of which can be relied upon because there is no way to medico-legally trust the information contained. However the identity data will be seen as very useful to the government, especially when cross -matched against internet and telecommunications metadata and other government databases.
Based upon our many concerns, we do not believe that the proposed changes to the system or the legislation will achieve any significant improvement in use by the health community
We contend that the government has only two alternatives: either decommission the system as soon as possible, or completely re-architect the system such that it is able to support major changes to existing health care work practices and is much better and more closely integrated with existing health record systems.
----- End Extract
Disclosure - I am a member of the Health Committee of the APF.
I have also found submissions here:
Here is the summary from the Office of The Australian Information Commissioner:

General comments

The OAIC welcomes the opportunity to provide the Department of Health with comments on the Electronic health records and healthcare identifiers: legislation discussion paper155 KB (the discussion paper).
The discussion paper outlines a range of proposed changes to the Personally Controlled Electronic Health Records Act 2012 and the Healthcare Identifiers Act 2010. The proposed changes relate to areas including governance, participation models, the obligations of eHealth system participants, and privacy. While section 3.5 of the discussion paper is named ‘privacy’, the OAIC considers that privacy considerations arise in relation to all sections of the paper. We have therefore commented on a range of proposals throughout the paper.
In making the comments below, we recognise the benefits that are expected to accompany an effective eHealth record system in Australia. These benefits include better health outcomes arising from the improved availability and quality of health information, fewer adverse medical events, and efficiency through reduced duplication of treatment.
However, changes to the eHealth record system do pose potential privacy risks. The system is expected to increasingly handle significant volumes of sensitive health information. In addition, the Government has announced trials of an opt-out model of participation, with the possibility of that model being expanded nationally in the future. Under opt-out arrangements, the health information of an individual who does not opt-out will be handled in the eHealth record system without that individual’s express consent.
In the context of an opt-out system, it is important to provide individuals with control over if and how their health information is handled, and to ensure strong privacy protections are in place for those who do not exercise their choice to opt-out. We consider that an eHealth system operated on an opt-out basis should be designed with privacy as a critical consideration. Ensuring that privacy is adequately addressed is fundamental to establishing and maintaining public confidence in the system.
We acknowledge that the discussion paper raises for consideration a range of privacy issues, and explains the Department’s approach to managing these. We welcome this focus on privacy as a central consideration. The specific comments below outline the OAIC’s views on the key privacy issues that in our view are raised by the proposals. 
The Consumers Health Forum responds here:
The College of Psychiatrists highlight some very serious issues here:
These two paragraphs raise an issue I have no idea how the PCEHR could ever properly manage
“The RANZCP also wishes to emphasise an important issue in relation to mental health diagnoses under the PCEHR system. Mental health diagnoses are often less clear cut than their physical health equivalents. Diagnoses can change as more information becomes available, research in the field develops or courses of treatment are found to be more or less effective. Therefore, a change in a patient’s mental health diagnosis is a common occurrence and -if previous diagnoses are not critically reviewed -it can and does result in many years of unnecessary treatment and stigmatisation of the patients concerned.
Consequently, the RANZCP considers that more information is required as to how the issue of a changing diagnosis will be reflected in a PCEHR. If a diagnosis is made by one practitioner and then reviewed, changed or removed by another, for example, how will this show up? Are there measures in place to avoid stigmatisation of an individual due to an incorrect diagnosis? Any PEHCR system would need to be flexible enough to allow easy correction of mislabelling and adjustments made as the result of new information coming to light or a change in presentation.”
This Google Search may soon find others:
(submission "Electronic Health Records and Healthcare Identifiers: Legislation Discussion Paper")
All in all there is some serious thought provided here. Will be interesting to see what responses we see. I bet all this is just ignored - but would be happy (no thrilled) to be proved wrong!
David.

AusHealthIT Poll Number 277 – Results – 5th July, 2015.

Here are the results of the poll.

Is Conducting Trials Of Opt-Out Of The PCEHR In Defined Geographical Areas A Practical and Implementable Idea?


Yes 5% (5)

Probably 13% (14)

Neutral 8% (9)

Probably Not 23% (25)

No Way 51% (56)

I Have No Idea 0% (0)

Total votes: 109

Seems a pretty good majority do not think the planned opt-out trials are a practical idea.

Good to see such a great number of responses!

Again, many, many thanks to all those that voted!

David.