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, March 07, 2007

Why the NEHTA Clinical Data Specifications Will Go Nowhere.

In early 2002 an organisation called the National Infostructure Development (NID) was funded to develop the information infrastructure that would be required as part of an implementation of the then planned HealthConnect. A key component was the Clinical Information Project (CIP).

The CIP focus was the clinical information content of shared EHRs for HealthConnect and the broader EHR agenda. The clinical information content relates to information that needs to be captured, stored and viewed to support the HealthConnect objective of improved delivery of health care and better quality of care.

Because the developmental focus of HealthConnect as a whole was based on the concept of event summaries, which were to make up the Shared EHR, the focus of the CIP was on the development of forms together with information content and definitions suitable for discharge summaries, referrals, result information and so on (the so called 'high priority' forms).

Efforts in this area continued when NEHTA took over responsibility for the CIP – since renamed a couple of times and, now seen as part of the Clinical Communications component of NEHTA's work. Recently (in December, 2006 and in February) we witnessed the release of two 500 page documents outlining the information structure and content of discharge summaries and specialist referrals.

What are we to make of these documents and how are they to be used?
_________________________________

In their introductory document the authors say:-

“NEHTA has released specifications to standardise the content of electronic referrals across Australia. This work also makes possible the development of improved decision support systems, which will be able to make use of the information in electronic versions of clinical documents (such as referrals) to assist healthcare practitioners make better decisions; and is an important step towards realising shared electronic health records.”

And they also say:-

A Comprehensive Specification

It is important to understand the philosophy behind specifying referral content as comprehensively as appears in this specification. The specification needs to be comprehensive to capture as much information as required for the recipient to understand the patient's condition as fully as possible. However, it is quite clear that any one referral sent by a healthcare practitioner is unlikely to require the full suite of details embodied in the specification. In developing the referral specification, NEHTA has considered:

• - how prescriptive the referral template should be, in terms of:

o structure;
o comprehensiveness; and
o the terminology used;

• - the burden imposed on clinicians creating and receiving referrals; and

•- the burden on clinical information systems to capture, send and/or receive and process structured information.

Therefore, while the specification is prescriptive with respect to structure, information richness, and terminology, it is not prescriptive about which information should be sent under what circumstances. It is important to note that the specification was also designed for use within clinical information systems to reduce the burden of data entry for the referring healthcare provider, and the subsequent data interpretation, storage and manipulation by the referred-to provider.

The specification and included samples therefore indicate the richness of information that can be expressed, sent and ultimately imported into clinical information systems and shared electronic health records. The specification should not be interpreted as the set of information that must be sent, irrespective of the condition of the patient and the purpose of the referral.

Implementation Considerations

The establishment of clinical information systems that can interoperate regarding the transmission and computer interpretation of referrals (and other documents) is an evolutionary process. NEHTA anticipates that, in the first instance, the health community will review the GP and Specialist/Critical Care Referral Content Specification to become familiar with the content and intention of the specification, and plan to implement elements of the specification where possible within planned system upgrades.

Once the additional elements required by interoperable systems become available, the systems that have incorporated the specification will be able to quickly transition to interoperability. The key additional elements are outlined below.”

____________________________________

The document then goes on to cite SNOMED CT, HL7 V2.x and provider and patient identification.

I must say it takes some special form of arrogance to publish a set of specifications such as this without any reference to, or suggestion of, even the simplest of trial implementations, or ‘proof of concept and viability’, or any of the tools that are obviously required to make any sense or use of the material.

I am sure any system provider offered this specification would say: “Where in the world is something of this structure and complexity working and how much are you going to pay me to be your trial horse?”

Comments such as “NEHTA anticipates that, in the first instance, the health community will review the GP and Specialist/Critical Care Referral Content Specification to become familiar with the content and intention of the specification, and plan to implement elements of the specification where possible within planned system upgrades.” provide no assurance any of this is going anywhere in the foreseeable future – and leads to the inevitable question “Why should I spend anything on all this until it is clear that others are?”.

The other obvious problem is that NEHTA says that one does not need to do a comprehensive implementation of this specification but provides no roadmap to guide development and implementation priorities. Unless this is provided this looks like it’s pretty much an 'all or none' in terms of what is needed to begin developing system specifications. And the “all” is a huge project I would suggest, especially as the specification seems to only exist as an untested MS Word document at present!

The last major issue is that nowhere in the documentation is there any mention of how interoperation, if ever attempted, will be certified and provide a robust guarantee of accuracy, reliability, future maintenance and safety. If you offer a specification of this nature for use you take on the obligation to maintain and certify compliance with the specifications that you produce in perpetuity. Plans in this area simply do not exist as far as I can tell.

Slipping back to reality for a moment, the facts are these:

1. A national HealthConnect project, as originally envisaged, seems to have a very low probability of actually ever being implemented, even though NEHTA says it is still being worked on. The most obvious reason for this is that the costs of such a project (almost certainly billions of dollars) are not likely to easily be provided by Government – despite a compelling business case to make major investments in the e-Health space.

2. The world has moved on to more pragmatic international standards with experts and implementers on both sides of the Atlantic seeking simpler and more practical implementable approaches for deployment of interoperable systems. In the US the Continuity of Care Document (CCD) is emerging (deploying features of HL7, CDA R2 and ASTM CCR) as a credible standard and in the UK work has been undertaken to reduce the information content on the NHS Spine down to the minimum possible.

3. Without a guarantee of major investment in these specifications no vendor will invest to develop compliance. Attempts at mandating such specifications are likewise doomed as large vendors will simply say 'you set up the certification mechanisms so compliance can be verified and you pay us all our costs at time and material rates and we will develop what you require!” Meanwhile, small vendors will probably be put out of business if they attempt to address the complexity inherent in the specifications.

4. Unless the specification is implemented as a whole how are partially compliant systems to ‘understand’ what they are being sent? There are also versioning and maintenance issues that will emerge over time that are not addressed as best I can see. What is likely to happen as new versions of this specification are developed or new terminology is implemented. All of a sudden interoperation between old and new versions will become much more problematic. OpenEHR and its predecessor designs have devoted vast effort to addressing such matters. It is not clear the same is true with this work.

It seems clear that as of now, NEHTA would be far better off working with HL7 to spend whatever limited resources are available to assist with and influence the CCD and make sure it is suitable for Australia rather than continuing with what is an ill-considered, go it alone, and now past its time, local initiative. That way, more local skills in support of a global standard and its implementation would be developed in Australia. This in turn would enable Australia to maintain a place at the 'top table' of standards developers, and ensure that it can draw upon various sources of implementation capabilities and resources internationally.

Unless NEHTA is prepared to fund a range of genuine ‘proof of concept’ implementations of its specifications (to confirm their functionality, utility, viability and technical correctness) this is all going to be a waste of time and money. Even if NEHTA does decide to take that path the likelihood of eventual adoption by the Australian Health IT community would have to be rated as unlikely at best.

David.

Monday, March 05, 2007

Why Should Commonwealth e-Health Executives be having Sleepless Nights?

NEHTA gave a presentation at the 9th Annual AFR Health Congress last week. This presentation confirms my worst fears. From the presentation it is now clear that fantasy and wishful thinking have replaced any rationality that may have once been evident.

I am now able to confidently declare the NEHTA experiment to be a dangerous, destructive (of many committed professionals in the area) and expensive failure, and I am confident it will soon become a 'career limiting' blot on the resumes of many of those involved.

It cannot be too long before the Minister is forced to intervene and try and rescue some of the worthwhile cargo from the sinking ship. How can I be sure? Let me provide the evidence.

Let's start with the title of the presentation “Accelerating e-Health in Australia”. This is hardly true – we are told in the presentation that the time frame for benefits realisation is 10 years and that current implementation plans for the most basic of services will take at least 3-4 years from now.

NEHTA claims to be managing four major projects. Let us consider each in turn

1. Benefits – Seeking to identify the greatest benefits for least cost, in the shortest time, with least risk

Great words but from where will the benefits come?

We are told the benefits will come from (presumed enhancements in):

“Safety –reduced incidence & severity of injury
Effectiveness –avoiding under-use, misuse & over-use
Patient-centeredness -supports continuity of care & patient self-management
Timelines –reducing queues, overcrowding, harmful delays
Efficiency –avoiding waste in equipment, supplies, resources
Equity –in location, socioeconomic status, ethnicity & gender”

What we are not told is ‘the how’. What systems, doing what, used by whom, paid for by whom, with what functionality and so on will yield this bounty?

The benefits are said to be coming from improvements in pharmacy, hospital and general practice processes, messaging efficiency and clinical decision support. How much more generic could one be. Of course if you put quality systems in to support these activities there will probably be benefits.

Work like this was done over five years ago in the US, UK and Canada and it was done better and provided much more detail regarding the systems required, the dependencies and the scale of investment required.

Furthermore the brightly coloured graphs provided are completely meaningless as they lack any scales, values or axes. I would suggest that benefits claimed without any quantification (or even estimates) are hardly real believable benefits. Where, one asks, is the information to support these slides – secret I suppose yet again – or does it actually exist?

Without this information what we have is a claim for benefits derived from systems we don't presently have and at present do not seem to have any plans (or funds) to purchase. It is fantastic – in the true sense of that word.

The two reasons to undertake benefits studies are to justify investment in Health IT and to assist in the management of benefits realisation during system implementation. What NEHTA provides is wholly inadequate to either task. Without much more detail one is left with the distinct impression no detail exists when it is clear a compelling case for investment can be made and should be made but this must be backed up by substance and free of the motherhood as provided here.

2. Identifiers -Uniquely identifying individuals and healthcare providers across Australia

This project has been overtaken by events. With the decision to implement the Human Services Access Card in April 2006, there should have been an immediate review by NEHTA of the plans earlier (February 2006) for identification management systems, to understand how the Access Card proposal could be best melded with the need for individual identification in the e-health environment before too much time and money were wasted.

This has not happened and any relationship between the two projects is disavowed by NEHTA. This is just silly! The facts are:

(a) The Access Card is intended to identify Health Sector Clients for Medicare Benefits and NEHTA is planning to use Medicare ID data for its Identifier.

(b) Both Projects are allocating citizens an ID number and establishing a data-base of basic demographic information.

(c) The NEHTA identifier will be allocated to citizens without their knowledge or consent and if errors occur the citizen will not have access to correct and view the information held.

(d) The NEHTA identifier is likely to be both less 'robust' and more potentially privacy invasive due to its covert existence.

I suspect NEHTA has been given some money and really wants to spend it – and that the ultimate casualty will be a very angry public when it is realised how they are all essentially being secretly numbered while at the same time having to obtain an access card. Again this seems to me to be 'career limiting' for the responsible bureaucrats if not remedied.

3. Terminologies -Exchanging clinical information electronically, using a common language with consistent terms, descriptions and formats.

This is important work but it is not being delivered at the pace NEHTA promised. It is clear the Australian Medicines Terminology extension of SNOMED CT (the national clinical terminology) is significantly delayed (it was promised for January 2007) and the work released on pathology terminology is, by NEHTA's own admission, not ready for implementation.

Without attributing any blame it is also clear that negotiations to set up the international Standards Development Organisation to manage SNOMED CT is also taking longer than expected. (It was meant to be done late in 2006).

4. Shared EHR (SEHR) -Designing a national system of shared electronic health records for authorised practitioners and consumers.

Work in this area would seem to have slowed to a dawdle with only a two page statement of intent issued in the last twelve months (in August 2006). I suspect those responsible have recognised that a national SEHR is much bigger and more complex than they ever envisaged when they were given the abandoned carcass of the HealthConnect project to resurrect in late 2004.

It is worth noting that the time frame for the review of SEHR Standards was twelve to eighteen months after the development of the original report on February 2006. Since that time very little progress seems to have been made with EN13606 (which is still not approved) and NEHTA has apparently declined the opportunity to further develop HL7 V2.x messaging templates as an interim clinical content transfer approach. Meanwhile there has been significant progress on the HL7 Services front and on CDA R2, CCR and CCD making much of the work done in late 2005 for the report obsolete and urgently in need of re-assessment.

5. The fifth project, which is only partially mentioned in the presentation is the development of Secure Messaging for the Health System and the associated Clinical Data Standards for a number of key messages (Discharge Summaries, Referrals etc).

Here we have the secure message providers (HealthLink, Medical Objects, Argus Connect, Promedicus.net, and others) essentially being forced into going their own ways – based on HL7 V2.x or PIT – and the Clinical Data Standards Project continuing on with work based on HealthConnect’s requirements of 2004/5 whilst essentially ignoring the now internationally standardised alternatives for practical health information sharing. It just gets sillier and more wasteful by the month.

What is to be done?

I think the first thing that is needed are the facts. For that reason, as I have suggested previously, I believe we need a professionally conducted enquiry into e-Health for the last decade to get out in the open all the secret reports and make transparent just what has gone well and what has gone badly. The enquiry should also include a thorough audit of the status quo in regards to NEHTA's activities, work-plans, project management structure(s), budgeting and financial controls. This is particularly important in order to see behind the corporate veil which NEHTA has constructed that enables it to avoid being subjected to the rigours of public accountability.

This enquiry would be like the independent enquires conducted in the UK by the Audit Office or in the US by the Government Accountability Office. It would be hard to argue that such a review is not warranted – even on the basis of the obvious facts that the initial vision of 2000/2001 has not been anywhere near delivered some six years later and to ask why.

Another reason an enquiry is needed is that I would argue we have never tried a real model of an AHIC (clinician and expert led) governing a technical execution arm. This is what I took the Boston Consulting Group report as aiming to set up. What happened is that the Government set up the technology component with largely only technology leadership and then moved it away from direct DoHA control and placed control with a non-expert (in Health IT) board.

To show how far implementation has slipped one only has to return to the April 2004 Boston Consulting Group Report. Three years following the report it was intended that:

“ Connectivity building blocks largely in place

- 'Critical mass' of new interoperable clinical and administrative systems

- Key standards agreed and implemented by authoritative body

- Significant broad band/required infrastructure roll-out across country

- High-system users aware of consent issues and electronic benefits

- Significant numbers of providers have experience of clinical messaging and order entry applications

- Expanded information available for research, policy purposes and administrative uses.”

How close are we now to this happy state? Look closely at what was recommended and compare with what we presently have.



Source: BCG April 2004.

It is only when armed with independently acquired facts that a really rational and workable forward plan can be developed.

For what its worth I believe that essentially the technologically driven 'tail' needs to stop wagging the health sector 'dog'. If the revised Australian Health Information Council (AHIC) had executive authority, a relevant mix of Health and Health IT experts and appropriate funds, it would be the ideal entity to take direct control of the NEHTA agenda and work plan. As this does not seem to be the case an alternative approach is required.

As I see it, the problem is that there really needs to be a holistic strategic and low level integrated approach i.e. all the aspects from identifying the problems, finding approaches and solutions, then doing the actual work [differentiating what should be done by the market and by Government(s)] in a co-ordinated way at the technical, standards and strategic levels.

Having a non-strategic 'tech shop', which operates in a strategic vacuum, and which claims strategic responsibility for Australian E-Health is a real problem - they (the Council of Australian Governments) have created a strategically 'headless chook' and we are now seeing the results.

So NEHTA has become the answer to a question that was not properly framed by the Boston Consulting Group - and this has led, combined with the dismemberment of AHIC, to the dysfunction we now see.

The reason we have gone down this path is that the business case, which should have been acceptable to Government to initiate a reasonable level of investment, was never done (as it was in the US, UK and Canada) and so, without any real investment co-ordination and scale, nothing has happened. And nothing will happen until that changes and this joke of an effort which masquerades as a business case from NEHTA (see the two colour slides) is redone to really get us there. There is good evidence available and this effort does not exploit it at all.

NEHTA does not see the gap between what it is doing and the need to have a real, achievable and immediate impact on health services (which is, I believe, huge).

We need a fully funded strategic e-Health entity which has the role of driving NEHTA down a more health sector focussed role and setting priorities for the whole sector - with a mix of vendor and home developed solutions and an openness to working with industry, academia, clinicians, and others.

It might be possible to add to NEHTA a strategy unit and a decent health sector liaison unit and change the CEO to someone more fitted to the role. The present leadership have shown an absence of strategic nous and health sector understanding and should only continue in operational delivery rather than strategic planning roles.

We also need to get real political accountability back - so heat can be felt and reacted to for the betterment of all! NEHTA really needs to be back under normal public sector management and accountability.

At HIMMS 07 (a few days ago) we had NEHTA deliver a presentation entitled “Successful E - Health Transitions: Australia's E- Health Initiatives”. Given what NEHTA has failed to deliver over the last three years or so, I would hate to know what failure looked like if this is success!

A major strategic change is needed, based on real independent evidence of what is working and what is not, and it can't come soon enough. The bureaucrats who are fond of their jobs really need to get a reality check, and initiate major change of the sort I outline, or suffer a pretty nasty fate once the Minister realises just how badly things have really gone, how many lives have been damaged or worse, and how much money has been wasted.

David.

Sunday, March 04, 2007

An Invaluable Reference on Health IT Value

Just a very short post to make sure everyone is aware of this invaluable site.

It is titled:

The case for IT in healthcare – supporting the patient safety agenda

It contains links and summaries of a large number of reports that have shown a clear case for using IT in healthcare to bring safety benefits for patients.

This is the case we should be making to the Australian Government.

The URL is:

http://www.connectingforhealth.nhs.uk/about/case/the-case-for-it-in-healthcare

Enjoy browsing and use the material to convince others of the importance and value of pressing on with Health IT programs and initiatives.

While citing this site it occurs to me there are other invaluable sites that are well worth a browse.

My special favourites are:

For the USA.

http://www.ihealthbeat.org/

http://healthdatamanagement.com/

http://www.informatics-review.com/

http://www.govhealthit.com/

http://www.healthcareitnews.com/

For the UK.

http://www.informatics.nhs.uk/

http://www.e-health-insider.com/

And in Australia

http://australianit.news.com.au/topics/0,7202,news_ehealth_law,00.html

http://www.pulsemagazine.com.au/

For a link to many Health IT Blogs – this site is useful

http://www.hitsphere.com/

Enjoy browsing them all.

David.

AusHealthIT Turns One!

Well the blog is one year old on March 5, 2007. It now has one hundred and thirty eight entries and a regular readership that exceeds one hundred and fifty different individuals each time a new article is added.

The current top 10 most read articles are as follows:

1. Personal Health Information Privacy – The Elephant in the Room

2. Archetypically Stupid!

3. Electronic Prescribing – What is Needed to Move Forward?

4. NEHTA’s Annual Report – What We are Not Being Told.

5. Privacy Issues Related to the Proposed Access Card.

6. E-Mail Security and Clinical Practice.

7. E-Prescribing in Australia – Is there a New Plan?

8. How Did iSoft Get into So Much Trouble?

9. Clinical Research Information Now More Freely Available on the Internet.

10. AusHealthIT's First Guest Blogger Article.

Amazingly the different pages on the blog have now been viewed 13,333 times since I worked out how to set up a site counter in May, 2006.

The steady growth in feed subscribers has been encouraging and suggests that at least the blog is of interest and slightly controversial rather than being a total bore!

Feed Subscribers


What is there to learn from all this regarding the current state of and planned directions for E-Health in Australia? I take the following from the level of interest and the comments posted.

1. The topic of Health IT (e-health) is of interest to many more people than would initially be thought.

2. The topics of interest are – with a few exceptions – centred around the need for better policy in the area.

3. The themes of the blog in suggesting the need for a substantive National E-Health Strategy, Business Case and Implementation Plan and clarity around the importance of Health IT in the areas of patient safety and quality of care are supported.

4. The need to have sorted out a plan and then to ‘get on with it’ using proven and known technologies is totally un-controversial. There is widespread amazement in the E-Health community that the opportunity cost of doing nothing in the e-Health space is unrecognised. It is costing the community dearly in both lives and dollars.

5. Frustration with the lack of strategic clarity in the e-Health space is forcing development and implementation activity which is to be welcomed but which could be so much more effective and valuable if undertaken in a supportive, rational and co-ordinated framework.

6. There is widespread disappointment and frustration that NEHTA has focussed too much on the “E” and not enough on the “Health” leaving its efforts being seen as largely irrelevant to the Health Sector in general and increasingly the E-Health Community in particular. It is very important for NEHTA to be successful for E-Health in Australia to prosper and right now it does not seem to be heading in the right direction or listening to the E-Health Community very effectively.

I sense change is coming in this election year and also that Year 2 will be a very interesting one!

I would love comments on the above.

David.

Thursday, March 01, 2007

HL7, Seemingly Moving Ahead as Australia Languishes.

Over the last few months there has been a steady stream of announcements and releases from HL7 that, taken together, must be seen as encouraging for the steady improvement in the level of standardisation and interoperation that is possible in implementation of e-Health.

These major announcements have (selectively quoting from the press releases) included:

1. On January 22, 2007 Health Level Seven (HL7) today announced four major milestones toward harmonization of interoperability standards as a result of the HL7 Working Group meeting held January 8 – 13, 2007 in San Diego, CA. HL7’s four key accomplishments include the following:

• HL7 collaboration with the Object Management Group (OMG) has resulted in HL7's Services-Oriented Architecture Committee successfully balloting three Draft Standards for Trial Use (DSTUs), two of which are now adopted and part of the Object Management Group's technology adoption process.

• Collaboration between HL7 and ASTM has resulted in the co-development of the Continuity of Care Document (CCD) endorsed by the Healthcare Information Technology Standards Panel (HITSP) and passed HL7 balloting on January 4, 2007.

• HL7 finalized an agreement with the California Health Care Foundation to ballot the EHR-Lab Interoperability and Connectivity Specification (ELINCS) through HL7 as an implementation guide to enable reporting of lab results from laboratory information systems to electronic health records (EHRs) in the outpatient setting.

• HL7 reached out beyond its existing membership, bringing extensive clinical input into the development of the EHR-S Functional Model. The Functional Model is one step closer to becoming an industry standard, and has already proven to be a useful tool for the Certification Commission for Health Information Technology (CCHIT).

2. On February 12, 2007 Health Level Seven (HL7), announced that, with the collaboration of the ASTM International E31 Healthcare Informatics Committee, the Continuity of Care Document (CCD) has passed HL7 balloting and is endorsed by the Healthcare Information Technology Standards Panel (HITSP) as the harmonized format for the exchange of clinical information including patient demographics, medications and allergies.

The CCD is a joint effort of HL7 and ASTM to foster interoperability of clinical data to allow physicians to send electronic medical information to other providers without loss of meaning, which will ultimately improve patient care.

“The collaboration between HL7 and ASTM reflects the integration of two complementary specifications [ASTM’s E2369-05, Continuity of Care Record (CCR), and HL7’s Clinical Document Architecture (CDA)] developed by separate standards development organizations, and demonstrates what can be achieved when patient care is the driving priority,” said Robert Dolin, MD, co-editor of the CCD specification and board member of HL7.

3 On February 21, 2007 Health Level Seven (HL7), announced it has passed the healthcare industry’s first ANSI-approved standard that specifies the functional requirements for an electronic health record system (EHR-S).

The standard outlines important features and functions that should be contained in an EHR system. The standard’s Functional Model contains approximately 1,000 conformance criteria across 130 functions, including medication history, problem lists, orders, clinical decision support, and those supporting privacy and security.

The function list is described from a user perspective and enables consistent expression of EHR system functionality, while the conformance criteria serves as a reference for purchasers of EHR systems and vendors developing EHR software.”

These announcements are all pragmatic and considered incremental steps in the level of e-Health standardisation and all have been either been proven through actual implementation or are provided as Draft Standards for Trial Use – and will only be made full standards once proven. I hope those responsible in Australia are monitoring the progress carefully and planning to take full advantage of the positive outcomes.

All this good news is not to deny that there are still some remaining issues with the HL7 project – most especially with HL7 V3.0. These issues are reviewed and discussed by a fellow blogger at the following URL:

http://hl7-watch.blogspot.com/

Having browsed his work I am sure Professor Smith would be as pleased as I am to see the continuing development of the HL7 V2.x standards while the complexity and wrinkles in Version 3.0 are worked through and a practical and fully usable standard emerges. Version 3.0 has now been over 10 years in the making so one can only hope it won’t be too much longer! There are some serious organisations (like the UK NHS) pinning their hopes on success soon. I also have a sense that NEHTA is developing specifications and standards which may require years in the implementation while from HL7 we are getting some real guidance that could move things along far more quickly.

On a related topic I happened to see a copy of the ISO/TC 215 Health Informatics
Opening Plenary Final Agenda and associated papers for the meeting of March 2007 in Montreal Canada. I have to say that I was surprised just how much of the material that was to be covered was termed to be in a ‘Preliminary” state. It would be good to see rapid progress at this meeting also!

David.

Tuesday, February 27, 2007

AusHealthIT Flash! February 27, 2007

Guess what?

The Australian Health Information Council (AHIC) has been reformed after some two years as the peak E-Health advisory body for Australia.

What is known so far?

1. The new AHIC has no executive authority or significant funds to disperse. It is purely advisory.

2. It has no more than two people in its membership who could be described as Health IT experts

3. It met some time last week apparently – but somehow the meeting date, time and attendees and topics discussed are a secret!

4. The role of the new committee is ‘Long Term Strategy’.

5. Apparently a communiqué is being drafted by DoHA so the great unwashed can get to know what is going on.

The time has come for all this to become a serious political issue as it is clear the present Government has no intent or capability to change things. Lives are being lost today as ‘long term strategy’ is being toyed with!

For the record www.ahic.org.au is still not operational (or .gov)

As the BBC says on their news website – “More soon”

For those interested my article of the 13 October, 2006 explains what is needed from a new AHIC. I leave it as an exercise for the reader to work out how close we have come in function, transparency and expertise!

Frankly, this is just hopeless. It seems to be secret, not well informed and impotent – just what the health system needs to manage the E-Health domain.

David.

Sunday, February 25, 2007

Its Really Nice to Know You Were Right!

Well the chickens have come home to roost! Even allowing for a fifty percent margin of error E-Health in Australia is only moving forward very slowly and is certainly not progressing with the urgency hoped for by Minister Abbott!

The goal was set in June 2005. A report, from that time, of the Minister’s remarks is as follows:

See http://www.computerworld.com.au/index.php?id=1737192765&eid=-6787 for the full article.

E-health put on notice

Health Minister Tony Abbott has put federal health IT bureaucrats on notice saying he expects tangible results within a year, specifically functioning electronic health records and accompanying smartcard system - or heads would start to roll.

"I am sick of trials and studies and working groups," Abbott said.

"I want patients to see a difference in 12 months. If patients do not see a difference, we will have failed," Abbot said, adding he was not prepared to be "held hostage" by a never-ending chase for the latest and greatest IT solutions.

"For too long we have tried to achieve too much. The best is the enemy of the good."

Asked whether he was prepared to force Australia's eight state and territory health systems to adopt federal health IT standards by linking their funding to outcomes stipulated by Canberra, Abbott said that state health ministers were as frustrated as he was with the seeming lack of progress and that there was no need for [force].

He was far less generous to federal IT practitioners.

"Maybe I should make some federal public servants' pay dependent on outcomes," Abbott said.
A spokesman for Abbott insisted the comment was made in jest, but that public servants were still required to deliver within the 12-month window. "Look, it can't go on forever," the spokesperson said.

As for whether the government is considering a "central database", the spokesperson said Abbott meant "you have to put the information somewhere."

And directly from a Speech in August 2005:

E-health is a high priority for the Howard Government. It was the subject of my first scripted speech as health minister. The subsequent 20 months have seen solid progress: the establishment of the National E-Health Transition Authority; the launch of a Medicare smart card in Tasmania; the beginnings of HealthConnect in South Australia; and the substantial completion of many of the trials necessary to enable the widespread effective use of IT in health care.

Think for one moment where these are now? Medicare Smartcard canned, HealthConnect on the deep backburner, and NEHTA now talking of a future taking many years before some real outcomes will be seen.

It seems pretty clear that for all the words – essentially zilch has really happened that has made any difference to the quality and safety of our healthcare system.

A good measure of the actual progress comes from the Department of Health and Ageing (DoHA) 2005/06 Annual Report (p133) where we learn e-Health initiatives have now impacted on10,444 consumers (of the possible 20 million or so).

The E-health targets that the report cites in the section reviewing last years performance, and which it claims have been met, are classics in goal post transport, reversal and remodelling. Rather than report on HealthConnect, which by no way could be said to really exist, the performance measures now relate to broadband installation and the establishment of NEHTA (which was largely in 2004/05 anyway). (p139).

On the next page we also discover E-Health was one of the reasons for the Government underspend on Health! (A $7+million underspend against a (very tiny) $50 million budget)

NEHTA and the DoHA bureaucrats must be wondering when the Minister will ask why it is being so slow spending the funds it has been given. (Note this excludes the other $130 million provided by COAG in February 2006 to NEHTA)

It can’t be said the Minister wasn’t warned. Witness the my comments, as reported in July 2005, after Minister Abbott said a EHR system would be operational in 12 months.

http://www.computerworld.com.au/index.php/id;1140691972

Academic says HealthConnect will not meet Abbott's timeframe

Michael Crawford 07/07/2005 09:56:10

Health Minister Tony Abbott's ambitious plan to have an electronic health record system operational is highly unlikely to meet a 12 month timeframe according to Dr David More, adjunct professor of Health Informatics at the University of Canberra.

Raising serious doubts about the federal government's ability to meet Abbott's strict schedule, Dr More said the only way the deadline can be met is if doctors get a working client system that is linked to HealthConnect up and running within the next few months.

Dr More, who is a Fellow of the Australian College of Health Informatics, said the government should have committed "real money" to an electronic health record system years ago.

"To have HealthConnect operational, doctors need to have a working and usable client on their desks immediately; this client will need to have advanced clinical decision support and use a fully standards-based infrastructure as well as provide for proper management of privacy and data security," More said.

"The task to develop and implement such a client nationally is just too big to be completed within 12 months. HealthConnect has so far been a seven-year project and look how far it is from that outcome today.

"Our medical system is based on a fee for service per item of service, so the incentive is for a doctor to get as many people through the practice as possible to maximize what he bills," he said, adding that the implementation of new technology will slow doctors down.

"Widespread adoption of a new client system will be slow without major financial incentives to make up for the costs and reduced income."

More also said the Australian medical software industry may not have the skills and expertise available to meet the demands of developing and implementing systems for a national electronic health system without a major injection of funds.

"The government needs to get serious about the amount of money it is prepared to spend in order to get such a system actually working," he said. "To try and duplicate the technology doctors already have would not make sense; they need intelligent, networked systems."

Dr More pointed to the UK's e-health program where the government has committed £10 billion ($23.5 billion) over 10 years.

The US has also committed billions to an electronic health record system over the next few years.

"Essentially we are talking megabucks to implement an advanced electronic system and to do it properly," he said.

In the 2005 Federal budget handed down in May, the government made available $20 million over three years for an electronic health record system.”

Given the article is essentially one large quote of my comments and is 18 months old I hope Computerworld won’t mind if I quote the article in full.

What is unarguable is that, while there have been some small steps forward, (I hear of some good things happening in small pockets all around the country) the lack of a coherent national strategy and reasonable funding ensures – as NEHTA now admits – we are still years away from an implemented and successful national approach.

Right now, it’s a hopeless mess that needs fixing. I hope someone is listening.

David.

Thursday, February 22, 2007

HealthConnect Mark II?

On the 21st February 2007 the Access Card Consumer And Privacy Taskforce issued a Discussion Paper Number 2. It covers the area of Voluntary Medical and Emergency Information being place in the citizen controlled area of the Access Card.

The rationale behind the discussion paper is explained in the introduction.

“In his address to the Australian Medical Association (AMA) National Conference on 27 May 2006, the then Minister for Human Services, Hon Joe Hockey MP stated:

“Importantly for the medical profession, there will also be space available for cardholders to voluntarily include vital personal information that could be used in medical emergency such as, next of kin, doctor details, allergies, drug alerts, chronic illnesses, organ donor status and childhood immunisation information. This information may save lives.”

In line with the Minister’s commitments, the Access Card Consumer and Privacy Taskforce has explored issues related to the storage of this personal medical information with the aim of developing a protocol which could be introduced at the same time as the registration process for the access card commences, that is in April 2008.”

It seems to me the discussion paper is typical of the sort of paper one would expect from a well meaning Taskforce which was blissfully ignorant of the issues surrounding the appropriate handling of potentially shareable identifiable clinical information as well as the nature of the requirements of emergency care providers for rapid access to some categories of information.

To address the second issue first – putting on my Emergency Medicine Specialist hat – the answer is easy. I want to know about any clinical history, current treatment or ongoing clinical condition that may significantly impact or change how I treat the patient in the hours before I can obtain such information from the patient’s family or doctors.

Addressing the first issue is a shade more complex and centres around how the information held on the card is to be created, maintained, verified, formatted, displayed and so on.

A sensible approach might be to use a standard template such as the ASTM Continuity of Care Record (CCR) or the HL7 Clinical Care Document (CCD). This would ensure all the relevant information, known to the clinician loading the card for later use, would be captured and that those looking for the information would become used to a standard data presentation and so be able to locate what they needed quickly. (I am unsure just exactly how much space would be required to successfully implement such a format but it is likely 20-30K bytes would be enough for most patient data requirements)

It is possible that if a standard format were used this information could be directly downloaded into the hospital computer system and thus quickly made available to all those involved in the patient’s care.

I agree with the Taskforce that it is vital all clinical information stored on the card be professionally verified and maintained. It seems unlikely practitioners will undertake such information gathering and recording without fee and consideration is required as to how such work is to be remunerated and indeed if the cost of such effort justifies the benefits that may flow. It is my view that before this additional application is added to the Access Card careful community cost benefit analysis should be undertaken.

Another significant issue is the currency of the information held in an Access Card and it will be important to ensure both that the currency of the information is clearly displayed and that appropriate business processes are developed to ensure updates are made as the information changes. Maintenance of the currency of information is an intrinsic problem when information is held on such a device – especially one that may not always be available for update. The now defunct HealthConnect program invested a lot of effort in defining all the approaches required for a central repository of shareable information but the Access Card infrastructure adds another issue in terms of the Card being only occasionally updated and the possibility of important information not being included.

An issue that is also possibly contentious – and will need to be resolved – is an approach to professional certification of the data loaded on the card. If the data read from the card is to be trusted by clinicians it needs to be recorded by the patient’s carer, verified for completeness and accuracy and then stored in a form that cannot be tampered with. Almost certainly some patients will have concerns regarding some information held on the card and there will need to be a very careful design of privacy and security controls to optimise benefit from the card.

All in all, as this paper stands, it is an inadequate review of the issues associated with use of the Access Card as a portable shareable Electronic Record – which is essentially what it is. I believe the paper is rather ‘half-baked’ and needs much more careful policy work and expert Health Informatics and Health Professional input before it should see the light of day as a serious proposal.

As a final comment I must highlight the following paragraph.

“The Taskforce draws attention to the fact that a significant number of submissions have canvassed a greatly expanded role for the access card in terms of linking it with other health records. The Taskforce is aware of the work being undertaken across various agencies to progress a national system of linked electronic health records assisted by the work of the National E-Health Transition Authority (NEHTA). The Australian Government has concluded that the access card program is not related to work being undertaken by NEHTA as this would represent a significant departure from the stated purposes of the access card.”

Just who is in denial of what here? Surely if we are all going to be given an Access Card and a number we don’t need NEHTA giving us another number? Any numbering of citizens I see as an essentially bad thing for a free society, but random non-government entities like NEHTA doing it is ‘over the pail’ in my view. A last point - just why does a company limited by guarantee not have a .com.au domain URL rather than a .gov.au?

David.

Tuesday, February 20, 2007

One Really Does Have to Wonder!

Being a slow Sunday afternoon (a week or so back) just after everyone has gone back to work after the summer holidays, I thought it would be a good time to have a quick look at the new and improved NEHTA web site.

Overall it looks good! Fast, easy to read and now having all the publications easily found and a special section for the newer ones so recent releases are easily found!

Thought I would check out the Links Section. Interesting finds here I must say! Six sites are included:

External Websites

1. Terminologies for the Australian Health Sector

This extranet contains the SNOMED CT download, and associated information on licensing, guides and tools. Access to the material is limited to those holding a current SNOMED CT license with NEHTA.

Comment: clearly a useful site for those needing access to SNOMED CT.

2. HealthConnect

HealthConnect aims to improve the flow of information across the Australian health sector.

Comment: Last updated February 2006 (on the site)with the latest news again seemingly posted in February 2006. This shows just how active the supposed central e-Health Project is in Australia – or maybe its all happening in secret and we will be told later! The site is a total mish-mash of just old and really archival material.

3. Healthelink EHR

NSW Health is piloting a new electronic health record called Healthelink in parts of NSW.

Comment: An invaluable site where an initiative begun before NEHTA was a twinkle in any-ones’ eye is referenced and where the last word in a non-NEHTA compliant privacy approach is being proudly deployed!

4. Australian Health Ministers' Advisory Council

The Australian Health Ministers' Advisory Council (AHMAC) charter is to provide effective and efficient support to the Australian Health Ministers' Conference.

Comment: A web site of a few press releases where the closest thing to e-health mentioned in the last 12 months seems to be the announcement of the removal of State legislative barriers to e-prescribing by March 2007.

5. AHIC - Australian Health Information Council

The Australian Health Information Council (AHIC) advises Health Ministers on how information management and information and communication technology can be harnessed in health care.

Comment: Here is what I got on 20 February, 2007 – and have for the last 3-4 months.

Server not found

Firefox can't find the server at www.ahic.org.au.

* Check the address for typing errors such as ww.example.com instead of www.example.com

* If you are unable to load any pages, check your computer's network connection.

* If your computer or network is protected by a firewall or proxy, make surethat Firefox is permitted to access the Web.

Overall one would have expected just a little better from a brand new site!

6. Standards Australia. Link to Standards Australia's website.

(Actually just the SA IT-14 Health IT Standards Site – not the full SA site.)

Comment: Interestingly this last entry appeared just in the last week or two – maybe following the exciting announcement of the new improved relationship between IT-14 and NEHTA.

This is a useful link so I will provide the URL:

http://www.e-health.standards.org.au/

Maybe next year’s revision could cover a more useful and informative collection of sites from around the country and the world. There is a lot going on out there. My personal top pick, along with an explanation of how the NEHTA projects and this project fit together would be to add the following link:

http://www.humanservices.gov.au/access-card.htm

We live in hope!

David.

Sunday, February 18, 2007

Some Gratuitous Advice for IBA Health Ltd regarding iSoft

In the last few days it has become an item of news in the UK financial press that the Australian E-Health Provider IBA Health is considering a purchase of iSoft PLC – the very troubled and probably near to insolvent UK E-Health Vendor.

Ben Woodhead provides good Australian coverage from February 16, 2007 at the following URL:

http://australianit.news.com.au/articles/0,7204,21235671%5e16123%5e%5enbv%5e,00.html

Right up front I need to make it clear I am an IBA Health shareholder but am not an iSoft shareholder – and that having purchased these shares at, or near, their low point a few years back – these shares have been pretty good to me!

It is also reported that the purchase is to be on the basis of a share-swap and that the ongoing operational funding for iSoft will be borrowed by IBA. The reason for this approach is that the on-going funding requirements for iSoft operations are almost certainly more than IBA's cash flow can reasonably support.

Some background (of IBA) is important here – the iSoft story having been laid out a while ago on the blog. (See “How Did iSoft Get into So Much Trouble?” dated October 21, 2006.). The key points are these:

1. IBA is really quite a small company employing of the order of 400 people (June 2006) compared with the approximately 3000 employed by iSoft.

2. In the most current year the company is forecasting revenue of $A74-76 Million with a profit of between $A23-24 Million.

3. The company has been driving for rapid growth in China, Malaysia and Singapore as well as Australia and has only recently purchased a development centre (December, 2005) in Bangalore, India. It is hard to see that these investments can possibly be bedded down.

4. The current market capitalization of $A525 Million really overstates the company size – given market capitalization was roughly one third of that only 12 months ago.

In summary I see IBA as a small-medium company which has been growing quite quickly, has made some sensible purchases to support its growth and is now well positioned as Australia's most promising e-Health company. Also the Asian expansion strategy IBA has been pursuing has been looking increasingly successful and given time looks likely to be very rewarding indeed.

iSoft on the other had is a 'rotting hulk' that has failed to deliver its major promise “Lorenzo” – an integrated clinical software suite for hospitals – and which is drowning under the weight of supporting a range of previously acquired legacy systems.

I am sure that the rationale IBA is contemplating is a 'once in a lifetime' opportunity to gain access to a range of large markets at a very low price. This may be true but the problems that have brought iSoft to where it is today are not going to be magically resolved by the purchase.

I also understand IBA's frustration with its limited success in its home hospital market over the last few years which it probably sees it can remedy through the acquisition of iSoft in order to gain access to sites in NSW and Victoria.

All this does not seem to me to provide a good enough reason to make such a high risk and potentially company destroying move. I say this from the perspective of an E-health specialist who reviewed iSoft's 'foilware' Lorenzo a year or so ago and was not convinced then of the feasibility of their vision – let alone their obvious inability to execute against that vision.

In summary, I think going forward with this merger is a 'bet the company' move which has an alarmingly high risk of failure and which will – almost certainly – have a bad effect on my personal investment!

The sell off (6%-7%) in the value of IBA shares in the period since the plan was announced suggests I am not the only one who thinks this move may ruin a wonderful Australian Health IT fairytale.

Some bargains just need to be left on the shelf!

David.

Disclaimer: The previous article is not offering any form of financial or other advice. Do what you think is right for you (Buy, Sell, Hold or Ignore) in the current situation and don’t blame me if you get it wrong!

Thursday, February 15, 2007

A Simple Person’s Guide to the Value of Health IT.

A colleague who is preparing university grant applications to fund his planned research in Health IT has recently challenged me to identify what I see as the value that can be derived from the implementation of Health IT. He is concerned that until a case is made that can be understood by laymen (read smart people who just know very little about the specific area) his job in obtaining funds will be harder as will my more general task of trying to sell the proposition to Government and other potential funders of investment in the area.

It considering the answer to the challenge it seems to me the best place to start is to consider what it is we want from an ideal healthcare delivery system. I would suggest the following are at the top of the desiderata:

1. The system should be safe and should not cause any harm either through action or inaction.

2. The system should utilise evidence of treatment efficacy and quality to guide patient care.

3. The system should be as cost- effective and equitable as is reasonably possible.

4. The system should operate as a supportive and interesting environment and be as stress-free as possible workplace.

5. The system should provide a co-ordinated seamless experience in managing a particular episode or care or illness with all those involved having the information they need to do their part without continued reference to the subject of care.

6. The system should, as a result of care delivered and with minimal extra effort, generate the information required to support functions such as academic and clinical research, post marketing surveillance of drug side effects, treatment outcomes, systemic system errors, general health system management and delivery of public health and bio-terrorism services and warnings.

If it is agreed these attributes are about right where the question to be asked is there Health IT in its generic form can make a difference.

Health IT can provide clinical decision support to those making the ‘life and death’ decisions and improve both the consistency and quality of the decision making – reducing errors of all sorts - saving both lives and money.

Appropriate use of Health IT can improve the accuracy of a clinician’s recall of a patient’s important attributes (allergies, current and past illnesses, medicines being used etc), ongoing clinical record keeping and in the process assist in the sharing of information between carers while also making available vital information for use in areas mentioned in point six. This is part of the importance of the electronic health record (EHR).

Health IT can assist in the increasingly overwhelming task of managing clinical knowledge and providing this information to those who need it. Increasingly the stream of information being generated by research and clinical trials is exceeding the capacity of clinicians to absorb the available information and to navigate available knowledge without help.

Health IT, as it has been seen to do in so many other fields of endeavour, can also replace much of the repetitive and drudge activities of the operation and delivery of health services. Service departments (laboratories, pharmacies etc) can be automated to maximise efficiency and quality of service, routine accounting and supply chain management can be optimised, photographic film can be replace by digital imaging improving both ease of use and eliminating film costs etc.

Health IT when combined with appropriate communication technologies can provide the information needed for safe consistent and properly co-ordinated care no matter where the patient is – from the surgery to the hospital to the home.

The combination of EHR technology and its implementation and use by the majority or practitioners, will provide the data-bases required to address the needs of research, management and all the other interests mentioned in point six above.

Of course there are potential risks, barriers and problems that need to be addressed. These include management of the security and privacy of identified clinical information, obtaining the proper levels of investment in appropriate technologies, having adequate trained practitioners to ensure proper system use, the proper allocation of the benefits flowing from Health IT deployment and use between all the stakeholders and having pragmatic standardisation of key areas of the technology to ensure effective system interoperation.

Nevertheless the benefits are demonstrable in all the areas mentioned above, have been proven to be there for the taking at a reasonable level of expenditure. All the risks are manageable and it is essentially just time to get on with it!

David.

Wednesday, February 14, 2007

Guest Article on Secure Pathology Messaging III - The AAPP Perspective.

Ann Webb, Deputy CEO of the Australian Association of Pathology Practices has written another contribution to the secure messaging discussion, from their perspective. This adds another view to the discussion for all to consider.

Ann writes:

In a guest blog by Dr Ian Colclough (see the entry for February 1, 2007) there were a number of references recently to the position held by pathology laboratories with respect to electronic messaging. It was felt by the Australian Association of Pathology Practices (AAPP) that a clarification of that position may be helpful.

Members of the AAPP provide more than 90% of community pathology services in Australia. The AAPP has a working group in health informatics and has supported standards development in this area for more than 10 years.

Among these standards were the Australian standards that Dr Colclough references for the implementation of HL7 v2.3.1. Indeed the Standards Australia Working Group that has carriage of the AS4700.2 and HB262 was formed through the efforts of AAPP member’s and in 1996 after formally reviewing the available messaging standards (including EDIFACT and PIT) unanimously endorsed the adoption of HL7 and immediately set about producing an Australian implementation guide.

This was first published in 1998 five years after PIT, a simple document format, was developed and adopted by pathology practices to get electronic messaging started in Australia. The structure for reports provides for the transfer of both atomic results and a rendering to ensure that the intended pathology report is conveyed with high fidelity.

Pathology practices have since been involved in a number projects to test and improve these messaging standards including communications with cancer and communicable disease registries.

The AAPP endorses ‘AS4700.2-2004 Implementation of Health Level Seven (HL7) Version 2.3.1 Part 2: Pathology orders and results’. Furthermore member practices currently provide significant volumes of electronic messaging to GPs, Specialists, and hospitals using these standard messages. The Pathology Practices are not the source of delay in widespread standardisation and would be pleased to move their customers to this mode of messaging now. The report receiving systems however have to be capable of managing these messages properly. That PIT is provided at all by AAPP member practices is because that is what their customers have asked for.

The AAPP continues to work closely with Standards Australia and NEHTA to establish the infrastructure that Australia needs for connected health care.

-----------------------------------------

Thanks Ann!

David.

Tuesday, February 13, 2007

What Might A Privacy Friendly Access Card Look Like?

In this short article I try to suggest there is a way to achieve the benefits of Smartcard technology and at the same time improve the service delivery and efficiency of the Commonwealth Human Services Department while avoiding much, if not all, of the present concerns regarding privacy and function creep.

The approach would involve the following:

1. Having an Access Card that has nothing more visible on it than its name (A Commonwealth Access Card) and a strip where the citizen can write their chosen ID (that could be their name but does not need to have anything to do with their actual name, address etc). (The card face has no photo, no name, no date of birth, no number etc).

An option, if required, for those who need to deal with services by phone, and need to quote a number might be to allow the ID number to be printed on the card at the specific request of the citizen. Normally most would not need this option as they would be obtaining a benefit at a point of service in person with their card.

2. The Access Card holds only four pieces of information electronically.

a> The card’s ID Number and

b> A quality photo of the card owner and

c> The unique biometric identifier code created from the photo and

d> A card expiry date.

3. The Commonwealth Secure Customer Database only holding the ID number, the citizen’s name and the biometric identifier derived from the photo (not the photo itself).

4. The Access Card being secured electronically so it is only usable by Commonwealth Government services authorised by legislation to utilise the Access Card using Commonwealth Government Access Card Readers.

5. The Access Card held information not being accessible by standard PC equipment or card readers.

6. Having the Access Card do nothing but act as a ‘key holder’ for Government services and nothing else (not a “mini-iPod”, e-Health Card, credit card etc)

How should the system be used?

First, when enrolling for an Access Card, high quality (“100 point”) ID is provided and temporarily stored against the ID Number that is to be allocated. At the same time the photo is taken, converted into a biometric, coded biometrically and also stored.

Next, once appropriate verification of the documentation is undertaken, the card is issued with the data mentioned above being stored on it. All information other than the name, the other data used by the electoral commission, the biometric ID code and the ID number are then removed from the secure database and destroyed. (This is necessary to prevent multiple cards being issued for the same person)

Internal Human Services Department systems use the ID number as their key and each collects all the other information they require for their operations when the card is first presented at say a Medicare, Veteran’s Affairs or CentreLink office. Each benefit thus has its own data-base to manage each benefit and linkage of these data-bases would be only permitted for reasons the public are content with.

All Government card readers will be photo display-enabled to facilitate display of the stored image of the customer, which is only held on the card and no-where else, and the name associated with the card. The ID Number is made available only electronically to Government systems and to no other requesters – even if they gain access to a Government card reader. Thus people delivering services can verify an individual’s ID and determine their ID number, but the card is useless to anyone else who is not an identical twin with the same name who can access a Government card reader and persuade the supporting system to provide its ID number. Still better, even if an ID number is known, it cannot be used without a matching card or specific consent from citizens who desire to access services over the phone and who are happy with the risks this involves.

If desired a PIN could be also used to maximise the security of access, even to the photo.

The benefits of this approach are:

1. There is no database created of every Australian Citizen that holds any more information than the electoral role with an ID number and a biometric ID (Note: no photographic image is held by government).

2. No photographic database of citizens is developed.

3. The card, having only a hand written “name” on it, cannot be used by anyone if lost. If use is attempted the embedded picture and the correct name will be displayed by the reader and this will disclose any attempted fraud to the Government operator.

4. If a citizen chooses to apply a PIN the card will be virtually useless if lost.

5. No one is going to ask anyone to produce a blank card to confirm their ID – especially when no useful information is available without a special Government reader. It will not become an instrument of control and oppression as the present proposal risks.

6. Function creep cannot happen except if the network of Government readers is extended and the citizen chooses to use the service that the Access Card enables.

7. The risk of a numbered card causing identity fraud disappears - there is no number on the card.

With this approach the Commonwealth has a strong link between the key it uses to deliver services and the presenting citizen seeking to use those services, thus it can control fraud etc but the card is – still as it should be – just an Access enabler.

The only downside of this approach is that, if the card is lost, full re-identification is required. That dis-incentive of itself should make most people pretty careful with their card!

The point of this commentary is to show it would be possible to design an Access Card system that would be privacy friendly and meet the Government’s objectives.

Why this has not been done is a mystery to me.

David.

Late Note:

In the Financial Review of the 13 Feb 2007 we now learn function creep is running on apace with, among other things, disputes breaking out with the banking sector of the recording of the Access Card ID in banking records and the rules for how such ID can be asked for. The banks say that having to get written consent to record and use the ID is too onerous. My position would be that an Access Card ID is no business of the banks whatsoever, consent or no! Extra function creep number two is that it seems a ‘voluntary’ Aboriginality flag is to be added – as requested by Medicare Australia. Will it never stop!

D.

Sunday, February 11, 2007

What Should be the Practical Outcomes of Health IT Privacy Protections?

In the last year, and most especially since awareness of the Human Services Access Card Project and the NEHTA IHI Project has increased, there has been a lot of legal and technical debate regarding these projects.

What seems to have been missing, for me, is a discussion of what is actually desired as the practical outcome(s) of whatever privacy regime we put in place and why each of those attributes is important. This is to forget for a moment how these outcomes are to be achieved technically but to recognise that in the design of any technical solution privacy has to be an embedded, fundamental design requirement.

My views have been formed from a range of sources, including a range of contributions to the Access Card Debate from the Privacy Commissioner and Prof. Alan Fels and his Taskforce, but I have additionally had the experience of consulting a range of interest groups in this area directly and the strength of their feelings has had a significant effect on my position. In saying this I must point out that with the exception of one or two ‘extremist privacy zealots’ who would require that a clinician were not to take any clinical notes and be subjected to a ‘brain wipe’ the moment a consultation was concluded, most groups and their representatives were balanced and totally reasonable in their concerns.

If I was to try and summarise what I have heard and continue to hear in a sentence or two it would be that people desire to have control over disclosure (to anyone) of health information they see as sensitive for what-ever reason and that if they feel they lack that control they become concerned or worse. There is also a feeling (belief) that health information – especially historical and diagnostic information – is different to financial and other private information in the sense that once disclosed it may not age or become less important over time (knowing a person’s bank balance or credit card number is likely to be only of importance for a short period of time – not so that an individual who has a genetic illness, has had a mental illness or has HIV / AIDS).

While not yet an issue of significant public concern it seems to me that, in an age where discoveries are being made daily, the control and sharing of genetic information will also become a major health information privacy concern over time.

There is also an increasingly pervasive feeling that exercise of control over one’s private information is becoming more difficult in the electronic age and that there is a reducing tendency to trust assurances as to privacy as individuals see their ‘private information’ turn up, unexpectedly, in the hands of all sorts of marketing entities and the like. Trust is also being eroded with the frequency of stories about improper access to information given in confidence to agencies such as the Australian Tax Office and CentreLink.

As yet it seems that most people are happy to share virtually all private information with the key individuals involved in their care on the general, usually unstated, proviso that they will be asked or give consent in some way and that they understand why such sharing is required. (Chronic disease advocacy groups are among those most keen for controlled but necessary information sharing). There are however some groups – especially those who could be described as having either stigmatising or embarrassing illnesses – who desire very considerable control of the use of their information at almost a ‘line by line’ level. If such groups are not provided with such control they will typically withhold information from carers, with the risk of poor or dangerous care being provided.

There is little doubt that individuals with HIV/AIDS, a history of mental illness and others are a major group of owners of multiple Medicare Cards. This permits them to receive care they may otherwise miss out on without disclosing to routine carers information they wish to keep to themselves. Just how this group will be catered for, reasonably, in the present Access Card and NEHTA proposals, is not yet clear to me.

The use of such ‘multiple identities’ is more common than is widely understood and is based on very well grounded fears of discrimination in all sorts of areas of life if some secrets are not kept. Latrobe University has, in a number of reports, highlighted the range and depth of discrimination and disadvantage suffered by many HIV/ AIDS patients.

It should also be noted that for many chronic disease groups the prospect of the use of de-identified information for purposes such as research and public health is strongly supported – just as long as there is no risk of re-identification of the information being possible.

Another poorly recognised issue on the part of city based health policy developers is the impact of even relatively innocuous unauthorised disclosure of information in smaller communities. (The ‘only gay in the village’ effect.) The impact of such disclosure can result in people needing to re-locate or worse and must be carefully addressed in any system design.

Of note also is the need to recognise that health information typically is associated with detailed demographic information (age, sex, address, date of birth etc) and that this information is true ‘grist to the mill’ for those who wish to trace people for whatever reason or who wish to steal identities.

Another issue not often discussed is the need to ensure flows of information to employers, government agencies etc is not prejudicial to gaining or retaining employment or receiving appropriate benefits and payments. Employers are certainly not equipped, in general, to understand or make sense of private health information, and should not receive it without specific consent. The same also applies to insurance companies, recognising that the citizen must understand that a failure to disclose germane information will most probably mean the coverage is void.

All in all it seems to me there is a perception emerging that control of one’s private health information is being steadily eroded and that this is not beneficial to anyone. As I have said before trust is lost if the citizen does not have the final say as to how, within reason, their private health information will be shared and used, and if that is permitted to happen E-Health will struggle to succeed in the way it should.

It is up to the proponents of the Access Card and NEHTA to ensure these ‘unexpected consequences’ of their initiatives are properly handled, that reassurances provided are indeed true and that we don’t create a class of disadvantaged and discriminated against ‘health information privacy refugees’.

David.

Tuesday, February 06, 2007

Where Could NEHTA Actually Add Value?

In this article I attempt to identify the tasks and objectives that NEHTA should be addressing rather than what is presently happening. The strategic perspective I am adopting is one that says there are two key priorities for virtually all health service organisations and that NEHTA’s efforts should be predominantly focussed on supporting, enabling and facilitation these two (urgent) priorities.

The two key priorities are that first health services should be safe and effective and second that health services should be economically efficient while being equitably accessible and distributed where ever that is possible.

The implications of ‘safe and effective’ include that no unnecessary harm is done, that needed treatments are not omitted and that where possible the care provided is based on up-to-date evidence. There is an implicit implication here that recognises that modern clinical practice is so complicated that only with automated support and well designed systems (both manual and electronic) can ‘safe and effective’ care be demonstrably delivered. Another clear implication is that all deliverers of care must be provided with the best possible tools and circumstances to ensure their patients have the best outcomes.

Efficiency and equity of access I would suggest are matters of common sense and common humanity. We should not be wasteful in delivery of care and we should ensure that all who need care can receive it without unreasonable delay.

Secondary priorities include the collection and management of information that both permits and enables the health system to operate in a coordinated and coherent fashion, be well managed and have a sensible balance between preventative and curative care.

Un-stated, but implicit in all of the above, is that everyone touching the health system is treated with respect, compassion and that their personal privacy and individual autonomy is fully respected and guarded.

NEHTA’s mission should be identify, specify, define and recommend the attributes of the Health IT systems required to optimally support the overall health system which has these objectives and goals. This it should be doing by working with the relevant stakeholders (including clinicians, relevant service providers (Pharmacists, Laboratories, Radiologists etc) ,Health IT providers, Health Departments and Institutions and consumers) to identify out what is needed and then develop innovative ways to have such systems delivered and a coherent fashion.

It seems to me, based on the Rapid Learning Approach identified in two recent blog entries, that where the main value lies is not so much in having systems, but having them actually used in the delivery of care. This means we need usable, quality systems, with rich functionality in decision support etc, in use in our General Practices, Specialist Offices and Hospitals. We also need to have them communicating successfully and safely the clinical information needed both to deliver care and understand what is happening out in ‘the field’. The systems also need to be able to ‘take care of business’ and thus appropriate links to Medicare Australia and other funders are important.

Additionally careful analysis of referral and prescription information and the associated systems is important. Also it is important not to ignore the needs of the public health sector in monitoring illness and warning of possible bio-terrorism. Analysis of where technology can assist in delivery of mental and aged care services is also needed urgently – although much is already known much of the relevant information seems a little fragmented at present in Australia.

On the basis that we know all provision of all the necessary systems is doable the first major task for NEHTA should be to develop a the National E-Health Strategy and Business Case and Broad Implementation Plan that, treating the health system holistically, maps a practical achievable and incrementally achievable roadmap of activities and investment.

Secondary activities should centre around utilising the work done both here and overseas to define and specify functionally the minimum standards for GP, Specialist, Hospital and Ancillary Systems. The CCHIT model in the US is one to consider with relevant changes to suit local conditions and business requirements for certifying systems once the system capabilities and connectivity is defined.

With hospital systems it may be valuable to develop common specifications against which State health systems can conduct procurements. Such systems are major investments and no doubt support from a skilled national entity would be welcome.

In essence what I am suggesting is that NEHTA should be working to ensure, as quickly as possible, quality systems are certified and health providers are able to procure / purchase them in the confidence they will be fit for purpose and deliver the benefits expected while having the basic levels of interoperability needed to enable practical information flows and clinical messaging around the health system. Note I am also keen that key enabling work, terminologies etc, also continue and that NEHTA be resourced to ensure deadlines promised to the Health IT community are actually delivered. That way the available products will be so much better!

It is up to the Health IT system providers to offer competent certifiable products and services and the health system to address how best to facilitate the required investment and ensure benefits are distributed to those who incur the costs and undertake the additional work.

I recognise that this outline is very high level and will require major change management. However, nothing here ‘rocket science’, the technologies are proven and implementable and the risks can be managed reasonably easily. Additionally the implementation can be phased and incremental so mistakes are learnt from and risk further minimised.

An approach of this type could, in a five year time frame, dramatically improve the safety, effectiveness and manageability of our health system. It would be good if NEHTA just forgot about identity management (others are doing it), academic interoperability frameworks, shared EHRs and the like for this period and facilitated getting the basic proven technologies implemented and used. Once the local operational systems of high quality are in place the challenge of enhanced information sharing can be addressed incrementally over time – just as is happening elsewhere in the world (witness the ground up Regional Information Network Approach in the US and the scaling back of the information content on “the Spine” in the UK NHS)

David.

Sunday, February 04, 2007

Australian E-Health Policy – Is NEHTA’s Board Steering in the Right Direction?

On the 30th January 2007 The Australian published a long article entitled “ Doing the numbers on e-health” by Karen Dearne which was described as the “world according to Dr Ian Reinecke” CEO of the National E-Health Transition Authority (NEHTA).

It seems to me that a sensible way to approach the article is to endeavour to distil what was being said or implied and to offer commentary on that basis. As the comments were made by the NEHTA CEO it seems fair to assume he is accurately reflecting the views and understanding of the NEHTA Board and it is my plan to address the apparent policy directions and choices being made by that Board, based on the position reflected in the comments documented in the Australian.

First it was obvious throughout the interview that NEHTA has no sense of urgency about advancing the e-health agenda. We are told that the business case for the National Shared Electronic Health Record (SEHR) may be ready for Council of Australian Governments (COAG) in 2007 (or if not 2007, hopefully 2008) although it was not clear, even if ready, whether it could actually make it onto COAG's agenda. Elsewhere we are told that (presumably) after approval has been given it will take three years (at least) to develop before it can be progressively implemented (over how long is not specified). What this says is that implementation may start in 2011 at the earliest and then proceed at presumably an equally relaxed pace.

Given Australia has been working on a variety of Shared EHR proposals since a House of Representatives Report in 1997 it is just flabbergasting that it can take a decade to get to the stage of developing a business case for e-Health which is yet to be completed or released. (The UK, the US and Canada did this years ago.) Worse it seems they are then prepared to wait another un-specified number of years to actually begin to deliver benefits in terms of patient safety and the quality of care – to say nothing of health sector efficiency. We know from studies overseas the opportunity costs of not implementing Health IT are billions of dollars in benefits forgone per annum (Canada thinks about six billion per annum in their country, which is similar in size to Australia) but it seems clear the NEHTA Board is content to just ignore such costs and proceed at the current leisurely pace. NEHTA itself, in documents published almost a year ago, has shown it understands this opportunity cost – so where is the action?

The lack of urgency with which NEHTA is proceeding becomes even clearer when it is recognised that responsibility for development of the SEHR was passed to NEHTA from the Commonwealth Health Department in April 2005. What progress has been made since then has not been obvious to this observer. Very little - is likely to be the answer given the interview comment like “A lot of that detail will start to move into the public domain, and (the SEHR) will be the subject of intensive work over the next 12 months”.

Second we are told by Dr Reinecke that “My understanding is that the access card will operate quite separately from the healthcare identifier. At this point there's really no place where the projects intersect.”

Just how can this be right?. The Access Card is going to allocate an identifier for use in the access of Health Services - how then can it be that this doesn't intersect with the identifier NEHTA plans to allocate for use in the Health Sector? If this proceeds all it means is that essentially every user of the Health Sector will have two identifiers on their health records – one from Minister Ian Campbell and one from NEHTA. I wonder does the Board understand just how bizarre and potentially wasteful this is?

Worse than that, the NEHTA identifier is likely to be the less robust of the two and yet it is the one that is intended to assure reliable linkage of health records rather than the much more carefully verified Access Card identifier!

Even more difficult to follow is that NEHTA thinks it can provide a health identifier for $15 million a year over three years ($45 million) and the Access Card project is costed at over $1.1 billion over about four years. Someone surely has their costings badly wrong?

Third we are told that it is NEHTA's preference to change the law so they can mine the most reliable of the Medicare client databases for names and addresses to populate their identity database.

I wonder what Professor Alan Fels of the Access Card Privacy Task Force and Ms Karen Curtis of the Commonwealth Privacy Commission would think of this proposal to covertly, and without consent, mine a Medicare database for details provided by citizens in good faith. My suspicion is that they would be gravely concerned. The Board should certainly make sure they are consulted (if it hasn’t) before any more money is spent.

Last we learn that NEHTA is confident the Standards it needs will be ready and that great progress is being made. This is true to the extent that we see the emergence of pragmatism and a sense of urgency in the US and also work in the UK to simplify implementation of HL7 V3.0. While progress is being made at a good pace on the Healthcare Services Specification Project Overview (a collaboration between HL7 and OMG) this work is unlikely to be ready for “prime-time” anytime soon.

It should be remembered that when NEHTA was conceived its job was to *quickly* choose amongst the available (and evaluated) standards - now it is trying to write the standards, which will probably take a decade to agree upon and even longer to generate the evidence that says they actually work. The much lower risk profile for using proven currently working standards versus scrapping them for their obvious defects (they will have these, by definition, of course) and going for long term high risk standards development has never been discussed, nor acknowledged. It is a fundamental shift in NEHTA's program, and seems to almost have happened by accident. Yet it is a profound shift. For this to happen without anyone worrying about it, seems to show an apparent loss of control on the part of the Board in its oversight of NEHTA’s direction.

Without rehearsing again all the other matters I have raised over the last month or two it seems to me that the NEHTA Board has not demonstrated (after two years) it is up to the task of providing National E-Health Leadership and delivering the required oversight to NEHTA. If NEHTA’s CEO reflects the Board’s priorities and views accurately, and I am sure he does, it is my opinion that, on the public evidence to hand, the Board is strategically inept, ill-informed, technically out of its depth, out of touch with the e-health community and stakeholders and their requirements and simply inadequate to the task.

It would be of value to the whole E-Health domain in Australia if the NEHTA Board was to produce a paper documenting their understanding of the issues raised herein and their proposed strategic action plan to address them.

I would also suggest a lot of the problems we now see are related to the loss of the Australian Health Information Council (AHIC) and its role in providing technical and strategic governance of NEHTA. AHIC is apparently to be re-constituted in the next few months (after a two year hiatus) but unless it is properly constituted, resourced and empowered this may be more of a hindrance than a help. We will see.

What I was hoping to hear, and didn’t, was that work on a National E-Health Strategy was well underway and that calls from a large number of stakeholders for improved pragmatism, responsiveness, transparency and consultation from NEHTA’s stakeholders and customers were being taken seriously and actioned. I would also have liked to hear that NEHTA was going to push for rapid progress in implementation of the Health IT applications and approaches that are known to work in saving lives and improving efficiency while pursing its long term R&D agenda. No such luck it seems!

The E-Health Domain is one area where a Commonwealth takeover and Commonwealth leadership is to be welcomed!

David.

Saturday, February 03, 2007

A Weekend Treat!

Just a short note to let everyone who has a moment on the weekend that the Robert Wood Johnson Foundation has posted a fabulous presentation on their web site entitled “Can Health IT Enhance the Pace and Power of Research? The Case for Rapid Learning Systems” dated Jan 23, 2007. The URL is:

http://www.rwjf.org/newsroom/activitydetail.jsp?id=10195&type=3

Those involved in the roughly one hour presentation are described as follows:

Carolyn Clancy, director of the Agency for Healthcare Research and Quality joins national technology experts, including David Eddy and Lynn Etheredge, to showcase ways in which EHRs are making rapid advances in diabetes and cancer care, how rapid-learning capabilities will help accelerate personalized health care, and how, through rapid learning, doctors will do a much better job of advising patients. Also featured are John R. Lumpkin, M.D., M.P.H., RWJF senior vice president and director of the Health Care group and Joel Kupersmith, M.D., Chief Research & Development Officer, Veterans Health Administration. (HHS Secretary Michael O. Leavitt, originally scheduled, is unable to attend.)”

This is a very serious cast and this presentation is by far the best way to gain an initial appreciation of the key contents of the Health Affairs special issue on Rapid Learning Health IT and its implications.

I would highly commend this to all readers of my blog.

David.