Submission on National Digital Health Strategy development

The Australian Digital Health Agency in 2017 has been charged with drafting a new National Digital Health Strategy on behalf of the COAG Health Council. This new Strategy will supersede the National e-Health Strategy published in 2008. The Agency will also have the prime responsibility for implementing the Strategy. Submissions from the community were called by the Agency in late 2016, and closed on 31 January 2017. CeHA’s submission can be found here.

CeHA submission on PCEHR & HI discussion paper

The 2013 Royle Review into the PCEHR resulted in 38 recommendations. Several years and one Health Minister later, some of those recommendations are finally being pursued by the Australian Department of Health. The Consumers e-Health Alliance submitted comments on the Department of Health’s Electronic Health Records and Healthcare Identifiers: Legislation Discussion Paper released in late May 2015.

CeHA’s submission can be found here.

PCEHR Analysis by Karen Dearne

With still no outcome following last year’s review of the PCEHR, former journalist for The Australian, Karen Dearne has provided her own in-depth analysis of the Personally Controlled Electronic Health Record program, based largely on Commonwealth Government Annual Reports covering e-health and PCEHR activities in the first two years of its operation.

Karen’s analysis report is available here.

Submissions to Dutton Review of PCEHR

CeHA has identified the following submissions to the Review, conducted in late 2013:-

Submissions to Review of Medicare Locals

Australia’s former Chief Medical Officer Professor John Horvath AO is currently overseeing the Australian Government’s review of Medicare Locals announced by Health Minister Dutton on 16th December 2013. Professor  Horvath is expected to provide his report to Government by March 2014.
Stakeholders have been invited to comment on various aspects of Medicare Locals’ functions including:

  • The role of MLs and their performance against stated objectives
  • The performance of MLs in administering existing programmes, including after-hours GP services
  • Recognising general practice as the cornerstone of primary care in the ML functions and governance structures
  • Ensuring Commonwealth funding supports clinical services, rather than administration
  • Processes for ensuring that existing clinical services are not disrupted or discouraged by ML programs
  • Interaction between MLs and Local Hospital Networks and other health services, including boundaries
  • Tendering and contracting arrangements
  • Other related matters.

CeHA has identified the following submissions to the Review:-

National Commission of Audit – some submissions related to healthcare

The National Commission of Audit was announced by the Treasurer, the Hon Joe Hockey MP, and the Minister for Finance, Senator the Hon Mathias Cormann, on 22 October 2013. Although the Treasurer has stated that the total health budget will not be cut, there have already been a number of “suggestions” floated publicly about how money for healthcare might be “better” spent. According to the Commission’s web site, the call for public submissions has closed. Whilst we wait for submissions to be made public on the Commission’s web site, the Consumers e-Health Alliance has identified a number of submissions that are relevant to the debate about healthcare spending, policy and governance:-

The following submissions address non health-specific areas  covered under the Commission’s terms of reference:-

In addition, a Senate Select Committee has been formed to inquire into aspects of the Commission of Audit. Submissions to this inquiry are progressively being published at:-

The Senate Select Committee is accepting submissions until 31st January 2014.

[ This page last updated 2014-01-17 at 2:30pm AEST. ]

Can the PCEHR be salvaged – a consumer view.

The Consumers e-Health Alliance is calling on the major parties to revisit the $1 billion national electronic medical information-sharing system and actually deliver the promised benefits.

CeHA convenor Peter Brown says the launch of the $1 billion Personally Controlled Electronic Health Record (PCEHR) “needs to be seen positively for the opportunities it presents.”

But with emerging difficulties identified by medicos, consumers, the local health IT industry and the full range of State and Federal government agencies charged with implementation, CeHA believes it is now important to bring all parties together to tackle the issues.

There is no way an effective e-health system can be established without standardised infrastructure providing quality interchange and secure storage capabilities for people’s confidential medical information.

We need to build on the basic PCEHR infrastructure by incorporating the many practical systems operating across the currently siloed health sector, but this has to be done in a co-ordinated, connected way. Such an approach is increasingly being undertaken elsewhere around the globe.

The original National e-Health Strategy, agreed by all Commonwealth, State and Territory Health Ministers in December 2008, addressed the need for a national governing body with an independent chair and broad stakeholder representation to set priorities, direction and funding.

Crucially, the National e-Health Governing Board would be publicly accountable for ensuring the desired outcomes, with the support of a new National e-Health Entity tasked with managing the work program, overseeing standards development, a privacy and security framework, and systems compliance. it will also co-ordinate the implementation.

It is unfortunate that these governance arrangements were not established from the outset. Obviously the co-ordination and management of such an inherently complex system would be a critical factor in its successful implementation and ongoing operation. That would achieve good quality co-ordination and collaboration of all stakeholders. This accords with the recommendations of the Health Ministers Conference, December 2008.

Instead, responsibility for operating the network has been handed to the federal Department of Health and Ageing.

Clearly, this was not initially envisaged, and the Department is not designed for such a task and has no prior experience in an operation of this size and type. Department secretary Jane Halton correctly pointed out recently that the national e-Health program was larger than the Snowy Mountains scheme. This is true, but the responsibility for that construction job was not given to a Government department.

The PCEHR system is far, far bigger than can be managed in that way. Healthcare not only involves millions of individual citizens and their personal medical records, but many thousands of organisations – public, private, sole practitioners, and some 800,000 employees.

It involves a new communications paradigm on a grand scale that will be strange to nearly every participating consumer and clinician alike; based on an appropriate electronic networking infrastructure.

It needs to be accepted that such an e-health network can only be made workable by having the four key stakeholder groups – clinicians, consumers, the medical software industry and government agencies – present at the same table at all stages of its development and implementation. The operation needs to be melded into a suitable type of network. This complex situation cannot be validly compared with the banks, since a health service is quite different.

CeHA believes consumer organisations can play an important role in articulating and clarifying privacy and confidentiality concerns, advocating for higher quality patient outcomes and more efficient use of scarce health resources through new technologies, and the use of patient data for medical research endeavours. And importantly, greater engagement with the patients themselves.

Good governance can help to de-politicise one’s electronic health record, by focusing on long-term infrastructure that can evolve to meet the needs and aspirations of clinicians and consumers.

Right now, it appears consumers can’t see enough value in the PCEHR system to bother signing up, and the Australian Medical Association has expressed its concerns in strong terms. Those that have signed up within the DOHA recruitment campaign are very disappointed to find the record content does not meet their expectations.

If we reflect on the conclusions detailed in the original National E-Health Strategy, recommended by Deloitte, they now appear as “unfortunately prophetic”:

“Implementation of the four strategic work streams needs to be undertaken in a tightly co-ordinated and concurrent manner in order to effectively deliver the national e-Health work program. Each work stream is highly dependent upon the success of the others.

“Appropriate e-Health foundations, in the form of computing infrastructure and consistent information standards, rules and protocols, are crucial to effectively sharing information across geographic and health sector boundaries. In this regard e-Health foundations can be viewed as analogous to an ‘information highway’ – unless the system is connected up in some uniform and rules based way, then in formation cannot move across the network.

“Foundations alone will not be of any value unless consumers, care providers and health care managers have access to specific computing solutions or tools to enable them to view and share appropriate health information. E-Health solutions will be the tangible means by which users can benefit from the building of a connected information network.

“The implementation of national e-Health solutions will similarly be pointless unless consumers, care providers and health care managers are motivated to use these solutions. This is a two way relationship as the quality of the underlying e-Health solutions will also play a critical role in driving stakeholder take-up and support of the e-Health work program.

Finally it is unlikely that any of this can be achieved unless supported by a governance regime which provides appropriate coordination, visibility and oversight of national E-Health work program activities and outcomes.

CeHA hopes momentum can be restored to the e-health program by adopting the recommended collaborative approach and initially keeping things simple by building on what exists.

We hope to work with the new government, post-election, to establish a truly independent National E-Health Governing Council that brings all stakeholders together, and to which a new operational entity tasked with implementation and operational responsibilities reports.

In this way, we can restart work on providing an efficient, useful, secure and economically funded patient information-sharing network that delivers important, agreed and prioritised benefits for all participants, which all stakeholders enthusiastically support.


Contact: Peter Brown, Convenor.

e-Health for Aged Care

CeHA representatives have been actively contributing to discussions around how best to capitialise on the significant investment in e-health by State and Commonwealth governments in recent years.

We have recently witnessed the Aged Care sector enervated with funding to support projects to help older Australians interact with the PCEHR, through such ventures as the Pathfinder Project.

CeHA, the Consumers eHealth Alliance, brings together the voice of a range of consumer organisations interested in harnessing information and communications technologies to provide better healthcare for all Australians.

In particular, we believe that this can best be achieved through a strong focus on the ’4 Cs’ – Communication, Cooperation, Coordination and Collaboration amongst all stakeholders involved in healthcare.