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."

Friday, September 04, 2009

International News Extras For the Week (31/08/2009).

Again there has been just a heap of stuff arrive this week.

First we have:

Demo shows IT critical to improving care of patients with chronic diseases

August 21, 2009 | Kyle Hardy, Community Editor

ANN ARBOR, MI and DANVILLE, PA – A five-year ongoing study involving 10 large physician practices across the country has so far shown improved quality of care for chronic disease patients from the use of health information technology.

The study, named the Medicare Physician Group Practice Demonstration, was launched by the Center for Medicare and Medicaid Services to enable physician practices to demonstrate that proactive and coordinated care has the potential for larger revenue savings. It is the first Pay-for-Performance project to work directly with physician practices.

The clinics that are taking part in this study include Billings Clinic, Billings, Mont; Dartmouth-Hitchcock Clinic, Bedford, N.H; The Everett Clinic, Everett, Wash.; Forsyth Medical Group, Winston-Salem, N.C; Geisinger Clinic, Danville, Pa.; Marshfield Clinic, Marshfield, Wis.; Middlesex Health System, Middletown, Conn.; Park Nicollet Health Services, St. Louis Park, Minn.; St. John's Health System, Springfield, Mo.: and the University of Michigan Family Group practice in Ann Arbor, Mich..

Of these 10 physician practices, the Geisinger Clinic and the University of Michigan Family Practice Group were two that showed improvements in a least 29 of the 32 quality measures tracked in the third year of the project.

"We focused on hardwiring reminders and alerts into the electronic health record to enhance care consistency and reliability particularly related to diabetes and coronary care as well as ensuring adults receive preventative health screenings," said Frederick Bloom, MD, assistant chief qualify officer, Geisinger Health System.

The Geisinger Health System, which encompasses 40 community practices in central and northeast Pennsylvania, has experienced improved quality of care while lowering the cost to patient from participation in the project. Through the use of their EHR system, the clinic was able to improve care on all 32 categories that include continuing programs for diabetes and coronary artery disease, adult preventative care, and hypertension.

"By participating in this project, we're able to develop more effective ways of consistently bringing quality and value to all our patients, not just the Medicare beneficiaries who are the focus of the demonstration project," continued Bloom.

Results were similar with the University of Michigan Family practice group. Of the 32 measured categories, the UM Family practice group improved care on 29 fronts. Care improvements were made in areas that included diabetes, congestive heart failure, coronary artery disease, hypertension, and breast and colorectal cancer screenings.

"The UM Faculty Group Practice invested significant time and resources in this project because it provided the opportunity to develop and test potential interventions that could improve clinical outcomes and reduce costs for patients with chronic disease," says David Spahlinger, M.D., senior associate dean for clinical affairs. "Our investments have enabled better coordination of care."

Much more here:

http://www.healthcareitnews.com/news/demo-shows-it-critical-improving-care-patients-chronic-diseases

This is an important study –as help for the chronically ill is an area where there is increasing evidence e-Health can make a real difference and save money.

Second we have:

Study Warns of Errors in Australia's Electronic Prescribing

Computer-generated prescriptions were completed with an 11.6 percent error rate at a large Brisbane hospital, twice the 5 percent error rate computed for handwritten prescriptions by the same staff employees, it found.

  • Aug 21, 2009

A new study warns the Australian government's plan to use electronic prescribing in hospitals by July 2012 could increase medication errors unless staffers receive enough training. The study, done at a Brisbane hospital and selected acute wards in Queensland, was conducted for the Australian Commission on Safety and Quality in Health Care. The study found computer-generated prescriptions were completed with an 11.6 percent error rate at the hospital, twice the 5 percent error rate computed for handwritten prescriptions by the same staff employees, Sydney Morning Herald health reporter Louise Hall reported Aug. 20. The Queensland trial was halted early, she added.

The review was published in the journal Australia and New Zealand Health Policy, which has announced it will cease publication in December 2009. The study identified "poorly designed software that automatically filled out scripts to the maximum dose and ordered unnecessary repeat courses," Hall wrote.

The commission's CEO, Chris Baggoley, said electronic prescribing can reduce medication errors and adverse events, but "there is a risk of introducing new errors if the systems are not correctly planned, implemented, and integrated into all the other systems of information operating in a hospital," according to Hall's report in the newspaper.

More here:

http://ohsonline.com/articles/2009/08/21/study-warns-of-errors.aspx

This just shows how misinformation published in the so-called mainstream press can just plain mislead people all over the globe.

See here for a discussion of what rubbish this article is:

http://aushealthit.blogspot.com/2009/08/useful-and-interesting-health-it-news_23.html

Third we have:

HHS to electronically collect hospital bed data for H1N1 flu season

By Mary Mosquera
Saturday, August 22, 2009

The Health and Human Services Department needs updates on a continuous basis on the number of available hospital beds available during the H1N1 flu season starting in the fall.

HHS consequently wants to collect data electronically through an online system called HAvBED, which it already uses in an emergency preparedness program to determine the bed capacity of the nation’s 6,000 hospitals.

During the H1N1 response earlier this year, HHS did not have an adequate understanding of the severity of the outbreak or the resources needed to respond to the crisis, such as ventilators and intensive care unit beds, HHS said in a notice in the Aug. 20 Federal Register.

A number of countries in the southern hemisphere have recently experienced a surge in seriously ill patients, leading U.S. federal health officials to anticipate a similar situation here in the next few months.

Reporting continues here:

http://www.govhealthit.com/newsitem.aspx?nid=72006

An obvious and important part of preparing for the US flu season.

Fourth we have:

HHS to industry: Help assess health IT networks

RFI asks vendors to submit ideas by Oct. 1

The Health and Human Services Department wants industry help to identify the current scope of health information exchanges and how best to foster a nationwide exchange for quality and outcome reporting.

The Centers for Medicare and Medicaid Services (CMS) on Aug. 20 published a request for information for the National Gap Analysis and Readiness Assessment for the Health Information Technology Infrastructure. The project is an outgrowth of the economic stimulus law, which provided HHS with $45 billion to be distributed to doctors and hospitals that buy and "meaningfully use" electronic medical records.

According to the RFI, vendors are invited to submit ideas by Oct. 1 on how to conduct a national scan of existing health IT infrastructures and how to “generate an initial national strategic framework for a national health information infrastructure,” according to the synopsis on the Federal Business Opportunities Web site. There is no guarantee of a procurement, the notice states.

The project’s goal is to support the adoption of electronic health records in the near term and lay the groundwork for broad exchange of patient data.

The entities to be included in the gap analysis and scan are federal agencies, such as CMS, the Health Resources and Services Administration, the Centers for Disease Control and Prevention, state Medicaid agencies, state public health departments, health information exchanges and networks and health providers.

More here:

http://fcw.com/Articles/2009/08/21/HHS-asks-industry-for-help-in-assessing-health-IT-networks.aspx

It is important to evaluate and analyse as you go along if you are going to be successful at the end of the day.

Fifth we have:

Websites Diagnose/Treat Mental Health

Assessing the Reliability of Medical Advice

By anya weimann

August 23rd, 2009 - 08:11 pm PT

While the Web is now a major resource for mental health information, many users and health experts are wondering about the quality of these e-resources when it comes to treating depression and preventing suicide.

From medical e-dictionaries and scientific online journals to virtual counselors and interactive message-boards, e-health sites focus on the exchange of information via email, the use of chat groups and the provision of 24/7 anonymous peer-group support under professional supervision.

According to the World Health Organization, depression will be second largest killer after heart disease by 2020 with studies showing that depression is already the second largest cause of death for those 15 to 44, for both sexes. The current credit crunch has exacerbated work pressures and family strain resulting in more people being diagnosed with some form of mental illness.

In Australia, independent health professionals and the Australian Department of Health and Aging increasingly direct attention to interactive, monitored communication forums, including BeyondBlue.com.au, depressionservices.org.au or webmd.com.

Much more here (registration required):

http://www.orato.com/health-science/websites-diagnosetreat-mental-health

Good to see there is some positive reporting on these excellent Australian efforts.

CDC Readies Internet Barrage To Combat Swine Flu

The U.S. Centers for Disease Control uses a range of Internet services, including Twitter, YouTube, and even games, to help spread flu-protection messages.

By Mitch Wagner, InformationWeek

Aug. 24, 2009

The Centers for Disease Control is preparing several electronic remedies to head off the spread of the H1N1 flu virus. The agency is planning to make use of Twitter, YouTube videos, and text messaging, as well as more traditional tools like e-mail blasts and Web pages. The goal is to saturate the Internet with information about how people can protect themselves against the flu.

The CDC is gearing up its efforts with the approach of autumn, and the flu season, and the possibility of a resurgence of the swine flu virus.

Central to the campaign is putting information on other Web sites, rather than requiring people to come to CDC.gov for information, said Janice Nall, director of the CDC's e-health marketing division. "We're trying to reach people where they are, not necessarily expecting them to come to us," she said. "All of our distribution is on channels that people are already using."

The agency has had some good experience with this approach, Nall said. H1N1 videos on CDC.gov have gotten about 100,000 page views, but the same videos on YouTube got 2.01 million views.

People look for videos on YouTube but not necessarily on the CDC.gov site. The videos are "nothing fancy," Nall said, some are just talking heads. "It's not like they're exciting, sexy videos," she said. "We're just trying to get the content out in video format."

More here:

http://www.informationweek.com/news/healthcare/patient/showArticle.jhtml?articleID=219401216

This is interesting inasmuch as the CDC is planning for their next winter in high summer. Looks like they will be able to make a difference.

Seventh we have:

Depressed people should get online counselling, study says

People suffering from depression should get counselling online to avoid long waiting times to see a doctor, according to new research.

Published: 7:00AM BST 21 Aug 2009

A study of almost 300 patients found that those given cognitive behavioural therapy (CBT) were two-and-a-half times more likely to recover from their mental health problems that those who received standard care from a GP.

One in six adults suffer from depression or chronic anxiety, and online CBT may offer an alternative to the growing problem.

Dr David Kessler, a senior primary care researcher at the University of Bristol and a part time GP, said: "The patients get up to ten one hour appointments which are carried out online by instant messenger.

"Maybe it is the writing things down that helps so much because you have to think more when you do this. It is like being in a chat room with your therapist.

"It would greatly improve access to therapists for people who are disabled, housebound or living in remote locations.

"And you don't have to be some whizzy computer geek to use it. Some of our patients were in their seventies although the average age of people with depression is surprisingly young – around the 30s and 40s mark."

In the study, patients aged from eighteen into their 70s were recruited from Bristol, London and Warwickshire and 149 were given online CBT along with the usual care while 148 got the customary GP sessions.

More here:

http://www.telegraph.co.uk/health/healthnews/6062089/Depressed-people-should-get-online-counselling-study-says.html

Another positive report on e-Health and Mental Illness support

Eighth we have:

ONC, Medicaid, to partner on state info exchange

By Paul McCloskey
Thursday, August 20, 2009

The Office of the National Coordinator’s Federal Health Architecture office is developing a version of its "Connect" software that would help expand health information sharing between Medicaid and other state health offices, as well as with federal and commercial health service agencies.

The project is a collaboration between FHA and the Center for Medicare and Medicaid Services’ Division of State Systems to produce a version of Connect that is enabled for the Medicaid Information Technology Architecture (MITA). MITA is a technology and business roadmap for Medicaid system modernization.

The joint-effort was announced at the Medicaid Management Information Systems conference in Chicago this week.

Leaders of the project envision that Connect could help turn legacy state Medicaid Management Information Systems (MMIS) into engines of health information sharing across states, where health and social services agencies have traditionally been disconnected from one another.

Connect is a software pipe designed by 20 federal health care agencies that allows organizations to exchange health information according to standards for the National Health Information Network.

Full article here:

http://govhealthit.com/newsitem.aspx?nid=71990

This work is gradually sending its tentacles out to all sorts of different areas of the US health sector.

Ninth we have:

Chemists to receive barcoded prescriptions

BARCODES are being added to all prescription forms issued by GPs in a bid to improve safety.

It is hoped that the two-dimensional barcodes will make it safer for patients as community pharmacists dispense prescribed medicines.

More than 1.5 million prescription items are processed each week by pharmacists.

The barcodes will help to eliminate errors that can occur when information is keyed into a computer from a traditional paper prescription.

GP practices across Wales will issue prescriptions containing a barcode, which stores the patient’s prescription information.

This can then be scanned – like a tin of beans in a supermarket – when the patient hands in the prescription to their local community pharmacy.

Information held in the barcode is then entered automatically into the community pharmacy’s dispensing system.

The barcode contains all the prescription information as well as the unique drug codes for each of the medications or preparations prescribed.

Each barcode can hold information for up to four prescription items.

Much more here:

http://www.walesonline.co.uk/news/wales-news/2009/08/24/chemists-to-receive-barcoded-prescriptions-91466-24513189/

Good to see Wales pushing ahead in this important area.

Tenth we have:

Clearinghouse Offers HIEs Free Platform

HDM Breaking News, August 25, 2009

As the nation moves toward a national health information network, some claims clearinghouses have noted that such a national infrastructure--the electronic data interchange networks for routing claims and related transactions--already exists.

Now, clearinghouse vendor NaviNet is making an overt pitch for state- and regional-level health information exchanges and regional health information organizations to use its network--for free--to transmit clinical transactions.

The Cambridge, Mass.-based vendor has sent a letter to the governors of all 50 states offering to make its NaviNet Health Information Exchange network available at no cost. The company would generate revenue via transaction fees paid by HIE users. The platform also would be free to regional HIEs and RHIOs that are state-designated entities. "If I'm the state, I don't need to build the toll road," explains Kendra Obrist, chief marketing officer at NaviNet. "The toll road is in place."

Each letter explains the company, its scope of business in the state and an estimate of annual savings generated in the state by use of the NaviNet network. The letter to California Gov. Arnold Schwarzenegger, for instance, notes 67,637 providers in the state are NaviNet users and saved an estimated $45 million during the past year through the efficiencies of electronic communications.

"Yet, while the benefits of establishing health information exchanges are clear, so are the challenges. In the last 20 years, we have seen community health information networks and regional health information organizations fail due to expensive and complex technologies, lack of funding and poor adoption," the letter states. "By utilizing NaviNet at no cost, California has an immediate opportunity to improve healthcare services for all of your citizens, reduce cost and create a better, more efficient healthcare system."

More here:

http://www.healthdatamanagement.com/news/NHIN-38876-1.html?ET=healthdatamanagement:e983:100325a:&st=email

This can’t be a bad thing!

Eleventh for the week we have:

VA glitch leads vets to false Lou Gehrig's diagnosis

By Jennifer Lubell / HITS staff writer

Posted: August 25, 2009 - 11:00 am EDT

A computer glitch mistakenly led more than 1,200 veterans to believe they had a fatal illness. According to the National Gulf War Resource Center, the Veterans Affairs Department erroneously sent out letters to veterans telling them they had “a diagnosis of amyotrophic lateral sclerosis,” or ALS, otherwise known as Lou Gehrig's disease.

As a result, the Gulf War veterans group was barraged by phone calls from veterans concerned that they had a terminal illness. “Many of these veterans went to private clinicians to get a second opinion. This second opinion outside of the VA is very expensive and can range from $1,000 to $3,000 or more,” the center said in a written statement on its Web site.

More here (registration required):

http://www.modernhealthcare.com/article/20090825/REG/308259979

Not a good look at all – more care definitely needed!

Twelfth we have:

HHS explains regional centers funding plan

By Joseph Conn / HITS staff writer

Posted: August 28, 2009 - 5:59 am EDT

The HHS officials in charge of setting up a national extension service to aid office-based physicians and other providers in the deployment and “meaningful use” of health information technology fleshed out details of the $694 million program during a Web-and-telephone conference Thursday.

As many as 1,250 participants logged- or dialed-in to hear and ask questions about the ground rules to apply for $643 million in grant money to be awarded over a four-year period to about 70 not-for-profit organizations that will run the regional extension centers.

The bulk of the money, $598 million, will be spent in the initial two years, beginning in 2010, getting the regional centers up and running. During that startup period, an estimated 90% of the funding for the regional extension program will come from federal dollars, with the balance coming from state or local matching government funds, foundation grants or fees the centers will be allowed to charge providers for their services.

The government estimates its subsidies of the centers will shrink to $45 million during the second, two-year period, as the centers move to self-sustainability and obtain 90% of their funding from local sources and fees. After four years, the regional centers will be on their own, expected to continue operations on whatever revenue streams they can muster without federal support.

A formal set of instructions on how to apply for the regional extension service grants and a separate summary of the program were published last week on the Web site of the Office of the National Coordinator for Health Information Technology at HHS.

Another $50 million has been allocated to a National Health Information Technology Research Center, which will serve as a resource for the regional program.

More here (registration required):

http://www.modernhealthcare.com/article/20090828/REG/308289957

The details seem to be coming quite quickly and attracting interest as expected.

Thirteenth we have:

Sen. Kennedy's absence leaves health IT void

By Matthew DoBias / HITS staff writer

Posted: August 27, 2009 - 11:00 am EDT

Sen. Edward Kennedy, who championed healthcare information technology legislation during his nearly 50 years on Capitol Hill, died Tuesday night at his home on Cape Cod after a year-long battle with brain cancer. He was 77.

“He will long be remembered as a champion for the causes he believed in. He leaves behind a long list of bipartisan legislative accomplishments, the impact of which will continue to be felt for generations to come,” said Sen. Mike Enzi (R-Wyo.), Kennedy's co-sponsor on the Wired for Healthcare Quality Act.

The wide-ranging health information technology bill, even though it passed preliminary legislative hurdles, ultimately died over privacy and other concerns.

The healthcare IT industry as well as the U.S. insurance market were profoundly influenced by Kennedy's legislative work.

Kennedy teamed with former Sen. Nancy Kassebaum (R-Kan.), who, as healthcare historian Paul Starr recounts, Kennedy referred to as “the kinder and gentler” senator from Kansas, in co-sponsoring a piece of bipartisan health reform legislation in 1996, then known as the Kennedy-Kassebaum bill. (Republican Bob Dole was the senior senator from Kansas at the time.)

More here (registration required):

http://www.modernhealthcare.com/article/20090827/REG/308279988

Senator Kennedy certainly did some important stuff in the Health IT domain. Vale Edward M. Kennedy.

Fourteenth we have:

Thursday, August 27, 2009

Electronic Decision Support for Medical Imaging Advances National Goals

by Scott Cowsill and Liz Quam

The Imaging e-Ordering Coalition's goal is to promote electronic ordering of diagnostic imaging services through the use of computerized clinical decision-support tools (e-Ordering). These physician-friendly tools help guide clinicians to order the most appropriate diagnostic test: the right test (evidenced-based) every time. Additionally, the process electronically documents the appropriateness of each order, providing value-assurance to the patient and measurable, comparable data to the payer (insurer).

e-Ordering Benefits

We believe that robust and swift health provider adoption of e-ordering for diagnostic imaging services is a key method to achieving the continuous quality improvement, cost savings, patient safety and care coordination goals of the Obama administration. Therefore, we are advocating that Congress move to include e-Ordering for Medicare beneficiaries in the final health reform package.

Further, there is currently an opportunity to incorporate a strong and more timely provision to promote electronic ordering of imaging studies with real-time clinical decision-support and with tracking and reporting functions into the administration’s definition of “meaningful use" of electronic health records. The members of the Imaging e-Ordering Coalition firmly believe that continuously improved care, with cost reduction for imaging services, can be achieved through the use of computerized order entry that includes an evidence-based electronic decision-support tool with a reporting function, and the ability to facilitate appropriate consultation with a board certified radiologist. These capabilities can and should be included in both ambulatory and inpatient EHR systems.

The e-Ordering tools are available for real-time support, derived from best-practices guidelines developed by the American College of Radiology, the American College of Cardiology, the American College of Physicians and other significant groups focused on clinical appropriateness. Such real-time, electronic tools must be able to attach the decision-support feedback regarding appropriateness to the claim and the record, thereby allowing quality reporting and measurement. Additionally, these tools can and must facilitate the ability of the ordering physician to undertake a collaborative discussion, when appropriate, with an expert radiologist to help guide the ordering decision.

Much more here:

http://www.ihealthbeat.org/Perspectives/2009/Electronic-Decision-Support-for-Medical-Imaging-Advances-National-Goals.aspx

Interesting stuff and clearly important.

Fifteenth we have:

Bradford plans Lorenzo expansion

28 Aug 2009

Bradford Teaching Hospitals NHS Foundation Trust is due to take Lorenzo live in a ward environment in the middle of September.

The trust initially deployed the electronic patient record system from iSoft in a weekly joint replacement clinic in April.

In a statement for E-Health Insider, the trust said: “The use of Lorenzo in our consultant clinics continues to go well, and further roll-out work continues to accelerate.

“The go-live data for ward-based requesting is scheduled for mid-September, enabling us to take advantage of a new software release that allows the system to be upgraded without any downtime. It also coincides with the arrival of our new intake of junior doctors.”

More here (registration required):

http://www.e-health-insider.com/news/5157/bradford_plans_lorenzo_expansion

Good to see Lorenzo is making steady headway.

Fifth last we have:

Pharmaceutical industry funding will help fight meth labs in Missouri, Kansas

By JOE LAMBE
The Kansas City Star

In Kansas and Missouri, new laws say a methamphetamine cook shouldn’t be able to get enough of his key ingredient to make a good-size batch.

Except that neither state can afford to fund the laws, which are intended to link pharmacy records and prevent multiple purchases of cold medicine.

As a result, a meth cook can go from one store to another, buying the legal maximum of cold medicine — a source of the key meth ingredient — at each store until he has all he needs.

That should change with the pharmaceutical industry’s offer to fund a linked database in Kansas and Missouri.

It is a move designed to better combat meth labs, and also could fend off attempts to legislate cold medicine into a prescription drug.

Final touches are being put on public-private agreements with the Consumer Healthcare Products Association.

More here:

http://www.kansascity.com/news/politics/story/1407865.html

Seems like industry trying to do something really useful with technology

Fourth last we have:

Assessing Demand for EHRs

HDM Breaking News, August 28, 2009

The Medicare and Medicaid incentives for adopting electronic health records will lead to a gradual build in demand for the software, rather than a surge, one investment analyst says. “That’s because some portion of the market will want to wait to see the final rules,” says Raymond Falci, managing director of Cain Brothers & Co., New York, who tracks public health care I.T. firms.

On Aug. 20, David Blumenthal, M.D., national coordinator for health information technology, predicted that the final definition of the “meaningful use” of electronic health records that will be used to determine eligibility for incentive payments under the economic stimulus program will not be available until the middle or end of spring 2010. The preliminary definition of meaningful use requirements will be issued by the end of this year, followed by a 60-day comment period, Blumenthal said.

This timing for defining meaningful use, which is later than many expected, may mean demand for EHRs will ramp up more gradually than if the details were known sooner, Falci says. Regardless, health care organizations are dividing into two camps: Those that are moving forward with plans to qualify for federal electronic health records incentive payments and those that are waiting for the final regulations on incentives, he says.

“A lot of hospital CIOs and group practice administrators have told me that they need to get started now” to ensure they qualify for maximum incentives by having a qualifying EHR in place by 2011, the analyst says.

Falci speculates that the federal government might wind up pushing back all the deadlines called for under the American Recovery and Reinvestment Act, much as it did when creating the rules to carry out HIPAA. “My guess is, in the big picture of what the government is trying to accomplish, they’re going to have to modify the timeline.”

Lots more here :

http://www.healthdatamanagement.com/news/ARRA-38893-1.html

I suspect the comments that demand will build only reasonably slowly will prove to be true.

Third last we have:

Law Firm Spells Out HHS Breach Rule

HDM Breaking News, August 27, 2009

The law firm Nixon Peabody LLP recently sent to clients an article explaining provisions of the Department of Health and Human Services' recent rule governing breaches of unsecured protected health information. Health Data Management received permission from the firm to publish the article. The firm emphasizes that the article is intended as an information source and readers should not act upon the information without professional counsel. Linn Freedman, a partner and head of the firm's health information technology division, is the author. The following is the article:

HHS issues breach notification requirements for covered entities and business associates

On August 19, 2009, the Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued an interim final rule ("the Rule") related to the Health Information Technology for Economic and Clinical Health Act (HITECH) requiring covered entities under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and their business associates to provide notification to individuals of breaches of unsecured protected health information to unauthorized individuals. In addition, HHS issued an update to its guidance specifying the technologies and methodologies that render protected health information (PHI) unusable, unreadable, or indecipherable. Section 13402 of HITECH, enacted on February 17, 2009, requires HIPAA covered entities and their business associates that "access, maintain, retain, modify, record, store, destroy, or otherwise hold, use, or disclose unsecured protected health information" to notify the affected individual and the Secretary of HHS following the discovery of a breach of unsecured PHI. In addition, in some instances, HITECH requires notification of a breach to the media. Covered entities must provide the Secretary of HHS with a log of breaches on an annual basis, and the Secretary of HHS will post the list of entities that experienced breaches of unsecured PHI involving more than 500 individuals on the HHS website.

Much more here:

http://www.healthdatamanagement.com/news/breach-38892-1.html

This is a useful discussion of the issues around data breaches in the US Health System environment of personal health information. There are ideas here we might consider.

Second last we have:

Online Patient Data May Open New Doors In Medical Research

Aug 25, 2009

"Since the Internet's earliest days, patients have used the Web to share experiences and learn about diseases and treatments. But now [advocates say] online communities have the potential to transform medical research," the New York Times reports. The latest development was spurred in part by patient groups like the LAM Treatment Alliance, which hopes to speed research on the fatal respiratory disease that afflicts young women. The group created "LAMsight, a Web site that allows patients to report information about their health, then turns those reports into databases that can be mined for observations about the disease."

More here:

http://www.kaiserhealthnews.org/Daily-Reports/2009/August/25/Online-data.aspx

This is a trend worth keeping an eye on – especially for the more unusual diseases it seems to me.

Last, and very usefully, we have:

Are Personal Health Records the Right Path?

Carrie Vaughan, for HealthLeaders Media, August 25, 2009

This past week, Vanguard Health Systems, which operates 15 hospitals in four states, joined a growing list of healthcare organizations and employers that plan to offer personal health records to patients or employees. Vanguard joined the Dossia Consortium of employers that have pledged to implement PHR software for their employees.

I wrote about whether personal health records would be a temporary fix or here for the long haul in the August 2009 issue of HealthLeaders magazine PHRs: Worth the Effort.

Given the emphasis on personal health records in the "meaningful use" recommendations by the HIT Policy Committee, it seems that PHRs are here to stay, which I, for one, believe is a good thing.

However, not everyone is convinced that PHRs are the right path for healthcare to take. Some physicians are concerned that the "art" of medicine is being replaced by templates and checklists and that electronic health records along with PHRs could suffer from the quality of data that is entered and exchanged. Other executives believe that the patient web portal may be the better solution.

That is the route Group Health Cooperative in Seattle took when it implemented its patient Web portal. Its philosophy is that the medical record should be a shared document between patients and caregivers that provides the same data to both of them, says Ernie Hood, vice president and chief information officer. The patient view of the information does include some additional definitions and health management information, he explains.

The challenge of PHRs is that until a large number of providers are interfacing with PHR products their use will be for the patients only--and a relatively small number of people currently maintain and actively use them, Hood says. Still, he acknowledges that PHRs will play an important role in the continuity of patient information as patients move between providers.

Much more here:

http://www.healthleadersmedia.com/content/237939/topic/WS_HLM2_TEC/Are-Personal-Health-Records-the-Right-Path.html

This and the link in the text are well worth browsing. Good perspectives on PHRs.

There is an amazing amount happening. Enjoy!

David.

Thursday, September 03, 2009

It Seems the Confusion Regarding PHRs and EHRs has Spread.

The following articles have appeared recently. Since the Conservatives are very likely to win the next general election what they are saying is very important for e-health in the UK. Do read on – there is some Australian relevance as well!

Conservatives pledge to ‘halt’ LSP deals

10 Aug 2009

The Conservative party has pledged to scrap the NHS Spine and halt and re-negotiate the two main contracts with BT and Computer Sciences Corporation in order to revamp NHS IT.

The promises came as the Conservative’s endorsed the findings of an independent review of the £12.7 billion NHS National Programme for IT, which has called for the five-year old project to be radically rewritten and the local service provider contracts to be “halted and re-negotiated”.

The role of the centre should also be confined to standard setting and catalogue procurement centrally “The catalogue should encourage smaller providers to innovate and develop solutions that better meet the needs of patients and the clinicians providing their care.”

The Conservative-endorsed review says the national NHS infrastructure, including the NHS spine, should be broken up; the LSP contracts held by BT and CSC halted and rewritten; and nationally procured systems replaced by a wider range of accredited systems chosen locally.

It concludes “the National Programme must not be abandoned”, and calls for an immediate freeze and renegotiation of the NPfIT local service provider (LSP) contracts. “Subject to any applicable constraints, halt and renegotiate the Local Service Provider contracts to save further inefficiencies with regard to cost and delivery”.

The focus for planning and decision making on IT systems should instead be passed back to local NHS trusts, with centre only retaining responsibility for essential infrastructure and standards.

The Conservatives and the review reaffirm the central objective of universal adoption of electronic patient records within the NHS, but say a new locally-based approach is needed to achieve this. To achieve this they say the two current two LSP-provided clinical systems, iSoft and Cerner, must be supplemented by a wider choice of accredited systems, through a framework catalogue.

Shadow Health Minister Stephen O’Brien said “The top-down bureaucratic National Programme has been plagued by delays and cost over-runs.” He said that without sight of the BT and CSC LSP contracts it was impossible to say how they could be changed, or how much had been spent or committed, but promised “there will be savings”.

Asked about the cost of re-negotiating the LSP deals, O’Brien said he was giving the firms advanced notice of a future Conservative government’s intentions and hoped to be able to work with them. But he also acknowledged getting out of current deals was unlikely to be cost free.

On the costs of a future re-negotiation he said: At the moment you have a lot of duplication, and have a lot of people trying to buy their own local systems and go outside the national contracts.”

The review says that personal health records – such as Google Health and Microsoft HealthVault – may have a useful role to play, but are no substitute for development of detailed local electronic patient records, which should remain the focus of NHS IT strategy. O’Brien said the Conservatives will launch a public consultation to find out how much control of their records people want.

More here:

http://www.e-health-insider.com/news/5109/conservatives_pledge_to_%E2%80%98halt%E2%80%99_lsp_deals

The reports and responses are here:

Links

Independent Review of NHS and Social Care IT (1.3Mb)

Conservative party response to the independent review

However on Page 3 of the second document they say the following.

3. PERSONAL OWNERSHIP OF HEALTH RECORDS

Governments across the world are introducing IT systems that enable greater personal control of health records.

France, Canada, the United States, Germany and Austria have all adopted IT programmes that include personal health records.

Patients in Canada and the United States have the option of storing health information on the web. In both cases, a local record is also held by the doctor overseeing a patient’s care.

Patients in France, Germany and Austria all hold electronic ‘smart cards’ through which they can access a record of their health information – data which is also held by the clinician in charge of their care, either on a central database or in local data stores.

We accept the Review’s recommendation that the NHS should consult with patients on how much control they want over their health records.

New technologies being developed by the private sector will enable individuals to maintain their own health records on a personal data platform, and to choose whether or not to share this information with third parties – all at little or no cost to the taxpayer.

Personal Health Records run by the private sector mean little or no cost to the taxpayer if they are procured in a fully developed form. Unlike the Government-run IT systems, which seem to be characterised by a tendency to let the taxpayer foot the bill for product design, the Conservatives would seek to purchase IT products that are ready for implementation. We would therefore save money and improve efficiency.

Greater personal control of health records can lead to significant benefits. It can empower patients, allowing them to share information with third parties if they choose to do so. Giving patients greater control of their data can also drive social and commercial innovation, and enable communities of patients to come together online and discuss their conditions and treatments.

In addition, personal control of health records can improve communications between patients and clinicians.

For example, patients can make comments on their records, adding details of additional medication being taken or other symptoms and conditions.

---- End Quote.

Yet again we have the implied suggestion that PHRs can replace provider systems. At least the review conducted by the professionals was clear that is not the case!

While on the UK I mentioned this a few days ago when discussion Shared Records.

Shared Record Professional Guidance (SRPG)

The purpose of the Shared Record Professional Guidance (SRPG) project was to develop a set of professionally led guidelines that would consider the governance, medico-legal and patient safety consequences of Shared Electronic Patient Record (SEPR) systems in primary care.

More here:

http://www.rcgp.org.uk/get_involved/informatics_group/shared_record_professional_guidance.aspx

The project report is presented in three documents:

SRPG final report (25 pages)

SRPG final reference report (140 pages)

SRPG quick reference guide (8 pages)

This discussion focuses on what is planned to be a detailed EHR which is made shareable – rather than the much simpler – but still tricky – sharing of a brief clinical summary. The most recent manifestations of the NEHTA IEHR seem to veer much towards the detailed rather than just a very limited summary. This would be a lot clearer if there was more information in the public domain!

These principles make it clear just how many issues need to be addressed to get it right. Read slowly and you will feel very tired indeed at the complexity of addressing all this! (Page 3 and 4 of the SHG) Note SEPR/sDCR stands for Shared Electronic Patient Record / Shared Detailed Clinical Record.

2. Principles for record sharing

Principle 1.

The success of SEPR/sDCR programmes should be measured alongside the operational characteristics of these programmes allowing evaluation of such systems in a wider context.

Principle 2.

Joint guidance on record sharing should be produced and maintained collaboratively by professional regulatory bodies and representative organisations to ensure a multiprofessional approach to record quality, consistency and clarity.

Principle 3.

A community using a SEPR/sDCR system should establish governance rules and processes that ensure the clear allocation of responsibility and define the rules and mechanisms for its transfer. The rules need to be clear on who has responsibility for content and for action based on the record content within and between organisations.

Principle 4.

SEPR/sDCR systems should be designed to support the governance principles outlined in Principle 3 (above).

Principle 5.

Health professionals should have a shared responsibility for maintaining and assuring data quality in SEPR/sDCR systems.

Principle 6.

Health professionals should be properly educated and trained to meet their legal, ethical and professional responsibilities for using and managing SEPR/sDCR systems. This should form part of their ongoing professional development.

Principle 7.

Semantic issues should be considered in the design and implementation of SEPR/sDCR systems so that meaning is preserved and must be sensitive to issues of language, interpretation and context.

Principle 8.

Governance arrangements should be in place to deal with errors and differences of opinion in SEPR/sDCR systems.

Principle 9.

Organisations should have the facility to update/correct erroneous information added to their DCRs from other sources, (with the original information retained in the audit trail).

Principle 10.

Content and provenance data should identify unambiguously the originator or editor of each entry in the SEPR/sDCR.

Principle 11.

SEPR/sDCR should to be able to store and present information in styles that meet the particular user’s needs.

Principle 12.

SEPR/sDCR systems should improve the quality and safety of care by facilitating communication and coordination between health professionals and informing best clinical practice.

Principle 13.

SEPR/sDCR systems should support structured communications between users (e.g. referrals).

Principle 14.

Health organisations should be able to explain to patients who will have access to their SEPR/sDCR and must make information available to patients about such disclosures.

Principle 15.

Health professionals should respect the wishes of those patients who object to particular information being shared with others providing care through a SEPR/sDCR system, except where disclosure is in the public interest or a legal requirement.

Principle 16.

There should be an organisational (or team) guardian with clinical and information governance responsibilities for that organisation’s shared and organisational DCRs, in order to assure best practice is followed.

As I said a few days ago, these are well worth the download!

David.

Wednesday, September 02, 2009

Why Does This Sort of Silliness Keep Happening?

The following appeared a day or so ago. It is fair to say it caused me to almost ‘choke on the Wheaties’!

Toolkit to cut hospital errors

Karen Dearne | September 01, 2009

A TOOLKIT intended to reduce medication errors in hospitals is under development for the Australian Commission on Safety and Quality in Health Care.

KPMG has been awarded a $320,000 six-month contract to produce a uniform electronic medication management system that addresses issues around prescribing by doctors, dispensing by pharmacists and administration of drugs by nurses.

Commission project manager Neville Board said the work, in conjunction with the National E-Health Transition Authority, "will optimise the safety of systems" being introduced to hospitals.

"While hospital pharmacists have been using computer systems to manage inventories and dispensing for some years, there are few examples of e-prescribing and electronic medication management to date," he said.

"This project aims to do a lot of the complex work -- developing tools to assess available systems and building up planning skills and resources -- so we can offer a robust, adaptable toolkit, rather than having each hospital start from scratch."

KPMG and Trilogy Information Systems will also design "an optimal e-prescribing screen" for users, based on the National Inpatient Medication Chart. The work is due for completion by next January.

More here:

http://www.australianit.news.com.au/story/0,24897,26007658-5013040,00.html

If I read what is said correctly the money is to be spent to ‘develop a toolkit’ to optimise the safety of medication management systems for hospitals who are introducing them.

The rationale for all this seems to be here:

Safe ePrescribing and Electronic Medication Management

There is a need for a comprehensive, best-practice standard set of safe procurement and implementation guidelines for facilities and Areas or states moving toward ePrescribing and electronic medication management (EMM). It is assumed and supported that electronic prescribing in hospitals can improve safety and quality. At the same time, there is potential to increase harm through poorly designed or implemented systems in hospitals.

It is important that tools are developed to ensure that EMM systems are implemented safely, and that their use optimises both safety and quality of care in the hospital environment. This work is a collaboration between National E-Health Transition Authority (NEHTA) and the Commission.

The Commission will be developing the following guidelines:

  • User requirements and procurement guide for hospital ePrescribing and electronic medication management (EMM) systems;
  • An implementation toolkit for ePrescribing and EMM in hospitals, including safe ePrescribing and EMM practice;

Consideration is also being given to the development of a standard optimal user interface which builds on the National Inpatient Medication Chart, as well as the national standard terms, abbreviations and units.

Contact:

Neville Board, Information Strategy Manager

(02) 9263 3587

Email: mail@safetyandquality.gov.au

The page is here:

http://www.safetyandquality.gov.au/internet/safety/publishing.nsf/Content/PriorityProgram-08_ePrescribing

What amazes me with this is that a consulting firm and a system developer – both with no apparent experience in the implementation of Clinical Physician Order Entry and Medication Management – including ‘closing the loop’ medication reconciliation systems is doing this work, rather than the experts from companies like Hatrix,(iSoft) and Cerner who already have years of experience in getting these systems right all over the world and who are already putting systems into operation in a number of States.

If the job was to work with current providers to optimise their implementations, this would be better done using clinical experts working with the system providers, not non clinical consultants.

I have absolutely no quibble with the need to do things properly and safely, but I thought that was what we paid the expert implementers to do, working with local clinical staff. I really wonder if we have the right parties in the room to optimise our outcomes for all.

I wonder what the evidence for electronic medication management being done badly is that has prompted this work. It is not clear to me, from the ACSQHC site, although I am aware there is old literature suggesting some early approaches were less than ideal. Readers of the blog will be aware that a publication developed by this same organisation was very badly flawed in an evidentiary and peer review sense.

See here – first topic.

http://aushealthit.blogspot.com/2009/08/useful-and-interesting-health-it-news_23.html

On this topic we actually have a National Prescribing Service which has a deep interest and understanding of this area (they have done great work with GP prescribing systems). I wonder why they are not working with the ACSQHC to establish what, if anything, is needed, and how it might be best delivered?

One also wonders where Standards Australia and IT-014-6-4 fit? There are a few experts there too!

Prescription Messaging

E.scripts will touch more Australians, more often, than any other clinical application

Replacing the simple printing of prescriptions with E.scripts involves the formulation of a prescription, supported by a relevant Clinical Decision Support System (CDS), and secure transmission of the prescription to the pharmacist, who then dispenses to the patient using associated software for data collection and reporting mechanisms.

More here:

http://www.e-health.standards.org.au/cat.asp?catid=46

Also who knows if there is any interaction eRX and MediSecure? Given it is a hospital based initiative probably not I would guess.

Overall, yet again lack for coherent governance for e-Health in Australia is having all sorts of miscellaneous projects thrown up without the right levels of co-ordination in my view. At the very least I would hope the project has a steering committee which has the NPS, relevant vendors, some appropriate expert clinicians and NEHTA on it to ensure time and money are not wasted.

Note that NEHTA does have a work program on e-Medication. See here:

http://www.nehta.gov.au/e-communications-in-practice/emedication-management

But there is not a new document published in the area on their website since 22/08/2006. Clearly this is an area of very high priority!

Without all these parties close to what is being done an impractical fiasco would seem to be a real risk.

David.

Tuesday, September 01, 2009

Woolly Thinking and A Lack of Clarity on E-Health Marr National Primary Care Strategy.

Another day and we have another of the Rudd Government’s trio of papers on Health Reform.

Building a 21st Century Primary Health Care System

The draft of Australia’s first National Primary Health Care Strategy has been released by the Australian Government.

31 August 2009

The Rudd Government today released the draft of Australia’s first National Primary Health Care Strategy.

The Primary Care Strategy focuses on what Government can do to improve the frontline health care that Australians depend on, including the care delivered by GPs and other frontline health professionals like physiotherapists, psychologists and pharmacists.

Australia’s health system is facing a number of key challenges including:

  • an ageing population
  • rising rates of chronic disease
  • the need to address the health needs of rural, remote and Indigenous communities.

The Strategy has a strong focus on meeting these key challenges of the future.

The strategy reinforces and builds on the work of the National Health and Hospital Reform Commission - providing the next level of detail that sits below the Commission’s broad priorities.

It provides us with a draft roadmap to guide future policy and practice in primary care in Australia, ensuring we are building a system that cares for the most vulnerable in our community and a system that is connected with the patient at the centre.

The Government is determined to get health reform right.

Stakeholder input has been crucial in developing the draft strategy, with more than 260 submissions received in response to the discussion paper.

Following the recent release of the National Health and Hospitals Reform Commission’s landmark report the Government has begun a national conversation on health reform with the Australian people.

Today’s consultation at Sir Charles Gairdner Hospital in Perth is the tenth consultation held by the Government. Over 18,000 hits have been received on the Government’s yourhealth.gov.au website – around 600 per day since the site was launched.

The three most popular topics explored on the site to date are hospitals and emergency departments, e-health, and primary care/general practice.

The release of the draft strategy today will further inform that discussion.

Development of the draft strategy has been assisted by an External Reference Group (ERG) with membership comprising primary health care experts from around Australia, including a pharmacist, a midwife, a physiotherapist, a psychologist, a general practice nurse, a consumer representative, primary care academics and strong representation from general practice, including those with Indigenous, rural and remote experience.

The Government thanks Dr Tony Hobbs, who chaired the ERG, and all members of the group who gave so generously of their time, experience and knowledge to inform the development of the draft strategy and its supporting report.

The release is found here:

http://www.health.gov.au/internet/ministers/publishing.nsf/Content/nr090831

There are two documents that were made available yesterday.

First we have:

Building a 21st Century Primary Health Care System: A Draft of Australia's First National Primary Health Care Strategy

Found here:

http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/nphc-draft-report-toc

The actual report is here:

http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/nphc-draft-report-toc/$FILE/NPHC-Draft.pdf

Second we have:

Primary Health Care Reform in Australia - Report to Support Australia’s First National Primary Health Care Strategy

This is found here:

http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/nphc-draftreportsupp-toc

The download is here:

http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/nphc-draftreportsupp-toc/$FILE/NPHC-supp.pdf

In the draft strategy we find the following under the Strategy Building Blocks:

2. Information and technology, including eHealth

eHealth and other technologies are key enablers for change in primary health care. eHealth will allow information to be available when and where a patient needs care, can drive communication and partnerships between providers and with patients, will reduce the risks of adverse events for consumers and, with it, reduce costs and improve patient outcomes.

Electronic information exchange, particularly individual electronic health records (IEHRs), are a strong support for multi-disciplinary primary health care collaboration and enable efficient exchange of information between the primary health care, community and specialist health care settings.

This would be a significant improvement on the current situation for clinicians and consumers, particularly those with complex or chronic health conditions and those who need to move across the service system – from a general practice to a specialist service provider or allied health professional to a hospital and back.

As Australians increasingly access online information and services through mobile and e-technologies, they expect that the health sector will operate as does other sectors, affording them similar access, efficiencies and ease of information and connection.

Consumers expect to be involved and active in their health care management, and should have access to tools to enable self-care in a structured and informed way, and assist them to navigate the health system maze effectively.

Released in December 2008, the National E-Health Strategy provides an appropriate basis to guide the development of eHealth and proposes the incremental adoption of IEHRs.

The National Health Call Centre Network, a Council of Australian Governments (COAG) funded initiative, provides a good infrastructure base for other innovative uses of technology, such as proactive telephone-based self-management support of patients and online health information.

What will be different?

Patients not having to repeat their medical history to each new provider. Patients having information to help them to manage their own condition. Health care providers able to set up virtual, integrated care teams, and having accurate and timely information to support best treatment. Potential to outreach to hard to service communities with more innovative and effi cient use of health workforce. Improved quality and safety.

In the Supplementary report we have information on e-Health in a major section, as well as comments it is important in pretty much anything.

This section covers pages 90 to 100 and is what I am much less than happy with.

Essentially these 10 pages say that e-Health is a good thing, the public want it and so we need to get on with the National E-Health Strategy and implement the notorious NEHTA Individual Electronic Health Record (IEHR)

Reading the 10 pages one gets the distinct impression the authors of this section have absolutely no idea just what the implications of what they are suggesting are, but that this is the latest buzzword and we think we should have one.

What they should have been saying is that what General Practice needs is broadband, connectivity, powerful, clinically useful provider systems for those in GP to use and standardised messaging capabilities to facilitate information flows between practices and within practices and with the various service providers and hospitals.

We also then need to exploit these systems to provide all the secondary benefits of information enabled practice.

If we can get there maybe then we can – as the National Strategy suggests - dip our toes carefully into clinical information sharing.

If you want an idea of just what a minefield this is download and read these documents from here:

Shared Record Professional Guidance (SRPG)

The purpose of the Shared Record Professional Guidance (SRPG) project was to develop a set of professionally led guidelines that would consider the governance, medico-legal and patient safety consequences of Shared Electronic Patient Record (SEPR) systems in primary care.

More here:

http://www.rcgp.org.uk/get_involved/informatics_group/shared_record_professional_guidance.aspx

The project report is presented in three documents:

SRPG final report (25 pages)

SRPG final reference report (140 pages)

SRPG quick reference guide (8 pages)

I am sure you will conclude, as I have, we have a zillion miles to go to get to first base before we go down the IEHR path. The issues and complexity make the problems around the IHI seem like a cakewalk!

Sorry but they really should have come up with a push for getting the basics right and have not over-reached as I think they have with this.

David.

Monday, August 31, 2009

The Privacy Commissioner Administers a Backhander to DoHA and NEHTA.

A few days ago the Commonwealth Privacy Commissioner released her submission to the Department of Health request for submissions on the legislative proposals for NEHTA’s Individual Health Identifiers.

The basic information on the consultation process can be found here:

http://aushealthit.blogspot.com/2009/07/having-worked-on-it-for-years-doha-now.html

The direct link is here to the DoHA page with a link to the request for submission:

http://www.health.gov.au/internet/main/publishing.nsf/Content/pacd-ehealth-consultation

Submissions closed on August 14, 2009.

Commentary on what was said by the Privacy Commissioner is found below.

No escape from identity scheme for Medicare

Karen Dearne | August 25, 2009

AUSTRALIANS may not be able to opt out of the planned national healthcare identity scheme despite assurances that those who do will still have access to treatment under Medicare.

Federal Privacy Commissioner Karen Curtis says "it is not clear how an individual will be able to exercise that option" under proposals on the national health ministers' agenda.

"We understand that any (authorised) healthcare provider or organisation will be able to obtain an individual's identifier from the (Medicare-operated) service without the consent of the person concerned," she said. "Potentially this could occur after treatment, when the person is no longer present."

Ms Curtis has questioned plans for a legal quick-fix that would allow the start of the Medicare-based identifier regime next year, saying the proposed service "is of sufficient scale and sensitivity to warrant specific new legislation to ensure consistency of protections and penalties nationwide".

Much more here:

http://www.australianit.news.com.au/story/0,24897,25975395-15319,00.html

The submission from the Privacy Commissioner is found here:

Healthcare identifiers and privacy: Discussion paper on proposals for legislative support; Submission to the Australian Health Ministers' Conference (August 2009)

.pdf (398.55 KB)

The key recommendations are summarised on the second page:

Key recommendations

1. The Office welcomes the opportunity to provide a submission on the Healthcare identifiers and privacy: Discussion paper on proposals for legislative support.

Part A

2. In relation to Part A of the discussion paper, dealing with the Health Identifier (HI) Service and the issuing and use of health identifiers, the Office has made a number of key recommendations:

3. The enabling legislation for the HI Service should cover:

i. provisions setting out the clearly defined healthcare-related purposes for which a provider can access the HI service to obtain an individual’s IHI and establishing that the IHI can only be accessed where the provider has a healthcare relationship with the individual

ii. prohibitions on use or disclosure of the IHI or associated personal information outside of the healthcare sector across all jurisdictions

iii. provisions which underpin the legislative status of participation agreements or provision for mandatory guidelines (see A.5.2 )

iv. requirements relating to independent auditing and mandatory reporting of breaches of HI Service policies

v. sanctions and complaint mechanisms (including a right of recourse to a relevant statutory officer like the Privacy Commissioner for the private sector and Australian Government agencies where appropriate), and

vi. provisions to ensure that any future expansion of uses of the HI Service is subject to a Privacy Impact Assessment and parliamentary scrutiny.

4. Obligations additional to those contained in the privacy principles should be established through a second-tier legislative instrument such as mandatory guidelines, and cover, amongst other things secondary uses and data security.

5. Clarification may be required in relation to whether administrative staff of healthcare providers will be able to access information in the IHI and Healthcare Provider Individual Identifier (HPI-I) databases, and if so how their use of those databases will be audited.

6. All jurisdictions provide for a common set of legislated obligations in relation to the collection and handling of health identifiers prior to the introduction of a wider common health privacy framework.

---- End Extract.

What I found quite interesting was the number of issues the Commissioner felt clarification was required.

28. The discussion paper states that use of the IHI will not be a requirement to receive health services.12 However, it is not clear how an individual will be able to exercise the option not to use their IHI. The Office understands that any provider with a Healthcare Provider Individual Identifier (HPI-I) and/or a Health Provider Organisation Identifier (HPI-O) will be able to obtain an individual’s IHI from the HI Service without the consent of the individual to whom the IHI has been assigned (if they have the required individual’s demographic information). Potentially, this could occur after treatment (when the individual is no longer present).

“31. The Office would welcome clarification of whether there will be any constraints on the circumstances in which a provider (who has the minimum demographic information required to search the database) will be able to access an individual’s IHI. For example, will a provider be able to access an individual’s IHI in situations where they do not have an active healthcare relationship with the individual and have not seen the person for a number of years?”

32. The Office is also aware that many individuals may be particularly concerned about specific health information that they consider more highly sensitive and want to have tighter control over the use and disclosure of that information. The Office would welcome clarification on what options the individual may have in relation to how they can exercise control over whether or not their IHI is connected to that specific information.

Participation Agreements in IHI.

44. The discussion paper suggests that additional obligations might be set out in participation agreements.22 The Office is unsure about the mechanism by which the status of such agreements would be underpinned by law, and would welcome clarification on this matter.

49. In relation to the remaining principles (openness, access and correction, and trans-border data flows), the Office agrees in principle that these principles should be regulated through existing health privacy laws and administrative arrangements. However, as discussed in sections A.6.2.3 and A.7, currently there are no specific legislative privacy protections for health information in the public sectors of two states (Western Australian and South Australia). The Office would welcome clarification of how this gap in privacy protections will be addressed.

60. The Office supports the intent of proposal 6, that is, that the HI Service Operator will disclose information held in the Service only to authorised users; and that the term “authorised user will be defined in the legislation. 29 The Office would welcome clarification of the scope of “authorised users”, particularly in relation to whether administrative staff of healthcare service providers will be able to search for an IHI or HPI-I (see A.5.2.6). It is important that the auditing process to determine who has actually accessed the service can adequately identify the actual individual who has performed the search. It is highly unlikely that a provider themselves will undertake the administrative work associated with accessing the HI Service, but rather that their administrative staff will be tasked with that responsibility.

74. The Office has previously expressed concern that the inability to specifically identify individual non-health care providers (such as administrative staff) may reduce the value of system logs and auditing as an oversight mechanism. The Office would welcome clarification of how this issue will be addressed.39

A.5.2.10 Anonymity

79. The paper states that the introduction of IHIs will not affect the ability of individuals to conduct health-related transactions with organisations and agencies anonymously where this is lawful and practical. 41 Although it appears from the statements in the discussion paper that it is theoretically true that individuals can choose to interact anonymously in a healthcare setting (by not using their IHI), in the Office’s view, this option may not be practicable for individuals, particularly once the identifier is linked to an individual’s health information by a provider.

80. The paper indicates that vulnerable individuals (such as victims of domestic violence) will be able to request that a pseudonym is used in conjunction with their IHI. In general, the Office supports the policy intent of providing consumers the option of using a pseudonym.

81. However, the Office is not entirely clear as to how the allocation and use of pseudonyms will work in practice. The Office would welcome clarification on this matter including:

- is the use of a pseudonym intended to protect an individual’s identity from being known by a health practitioner and/or by staff of the HI Service Operator?

- whether this feature will be available to any person enrolled in the HI Service, and if not, what criteria would determine entitlement?

- what process would individuals have to complete in order to use this feature?

---- End of Extracts.

What is being said here, as noted in the report, are a number of crucial issues, which when thought about, may prove very difficult to manage.

First it is assumed that access to the IHI will be auditable down to the level of the individual to prevent unauthorised access. If access to the service is extended to provider staff (categories not defined) then all these staff, as well as all providers, will need secure robust ID as provided by proposed National Authentication Service for Health (NASH). Given one can be sure that providers themselves are not going to be looking up and checking IHI’s we have just added a huge number of additional individuals who will require IHI tokens – or admitted the IHI access will not be properly auditable.

Second it is obvious that NEHTA and DoHA have not worked out how to prevent providers using the IHI once they have once obtained it, even though an individual’s circumstances may have changed making it important links not be made. Given everyone is to allocated an IHI it seems no one has really worked out how to ‘un-allocate’ an IHI, even when requested to do so. (The point numbered 28 puts this issue very clearly I must say!)

Third it is clear the Privacy Commissioner is concerned that jurisdictional legislation is lacking in WA and SA and that this really means a Federal Act with overriding authority before any of this can come into operation.

As the Office says “ Given the lack of uniform privacy regulation it is important that national projects involving personal information or potentially sensitive information of all Australians, such as the HI Service, have dedicated, project-specific legislation ensuring that consistent privacy protections apply regardless of jurisdiction.” (Point 35).

Last it is clear the Office believes there need to be very good reasons why Privacy Impact Assessments are not made public – with some possible excisions for security – after they have been completed and appropriate modifications made.

As the Office makes clear here:

“36. As the Privacy Act is principle-based and technology neutral, on occasion additional privacy protections are warranted and necessary to regulate large-scale initiatives that involve the handling of personal information in new ways, such as with the Tax File Number, credit reporting information and MBS and PBS claims information.16 The Office believes that the HI Service is one of these comparatively infrequent national initiatives requiring specific additional privacy regulation.

37. This is consistent with the ALRCs view that legislation relating to shared electronic health systems „should deal with those issues that fall outside existing privacy regulation and provide more stringent rules where necessary”

And here:

“11. While other large databases exist in Australia, such as those maintained by Medicare Australia and by the Australian Taxation Office, a very large number of users will interact with this repository whose access thus needs to be carefully handled with adequate legislative protections to minimise any potential for misuse.”

This project is very large, many are going to have access and individual’s details need to be very well protected. Reading this submission I do not believe the Privacy Commissioner is in any way comfortable yet that this is the case.

I think there really needs to be an exposure draft of the actual Federal Legislation and a further period of consultation with the public before we move forward.

David.