David More wrote:
> Hi All,
>
> Those interested in NEHTA COAG Announcement and what they think it means
> should go here
>
> http://www.nehta.gov.au/component/option,com_docman/task,cat_view/gid,92/Itemid,139/
>
That all seems remarkably sensible - and the press release itself is
remarkably informative (as press releases go) and refreshingly free of
bafflegab.
A few observations:
1) A minor worry is the following sentence regarding SNOMED CT:
"The funds will be used to establish a national capability to develop,
maintain, distribute and support SNOMED."
It is the verb "distribute" which worries me. Please, please, please
NeHTA, do what the Yanks have done and make SNOMED CT freely available
to anyone and everyone in Australia for all healthcare and
health-related purposes - in which case no funds are needed to
distribute it, it is just freely downloadable - and please, please,
please DON'T, for the love of any or all deities of your choice, do what
the Poms have done and set up a set of impenetrable bureaucratic
processes which must be negotiated before licensed copies of SNOMED CT
are reluctantly handed out to "approved organisations" which are
required to make Faustian bargains for the privilege.
There are two main reasons for this plea:
a) take-up of SNOMED CT as a lingua franca will be severely hindered if
it is hard to come by, even for casual use; and
b) there is an opportunity here for enormous local informatics and IT
innovation in the way SNOMED CT is used and incorporated into just about
every existing and new clinical and health information system. Much of
that innovation will be done on an open source basis (in universities
and small start-ups), to the benefit of everyone - but that won't happen
if the substrate for such organic growth - the substance of SNOMED CT
itself - is not freely available.
2) The total budget, particularly for the unique healthcare identifier
initiative, may well be a bit underdone as David More asserts, but we
mustn't forget that health care authorities, at the Federal, State and
regional levels, as well as private health care companies and
organisation, currently spend a lot of money on (and are planning to
invest more money in an effort to improve) patient registration
processes, unique patient identifiers and in maintaining health service
provider directories. If NeHTA can convince these entities to redirect
these resources to the national equivalents which it proposes will
subsume them anyway, then there will be enough funds and person-power to
make it work (in particular the unique patient identifier, which is the
biggy).
3) The privacy implications of a single, unique healthcare personal
identifier need to be carefully considered. I am NOT saying that we
should not have such a thing, only that that any unique number
necessarily poses some additional risks to privacy (as well as many,
many benefits which undoubtedly outweigh the potential risks) - but it
behoves anyone proposing such a national unique identifier to ensure
that it is implemented in such a way that minimises those privacy risks.
The NeHTA proposal to separate the storage of IHI (individual healthcare
identifier) from the identity ("demographic") information (name,
address, DOB, sex etc) with which it is associated sounds like a
promising start, but it is unclear how they propose to actually achieve
this. If they mean a purpose-specific IHI ID number proxying process as
described in this paper, then I'm all for it:
http://www.biomedcentral.com/1471-2288/3/1
4) Wearing my public/population health hat now, could the definition of
"healthcare provider" please be made broad enough to encompass all
professions involved in health, including those not engaged in direct
patient care (eg public health people, health researchers, even health
care managers). They are all part of the rich fabric of our diverse
health system and they all need to be communicated with.
5) If a national HPI (healthcare provider identifier) is to be
established, then please, please could this be associated with:
a) a lightweight PKI which also encompasses all, or the majority, of
people to whom a HPI is issued; b) a means of authenticating everyone to
whom an HPI is issued to Web-based services (this could also involve use
of the PKI) and c) a universally accessible, widely replicated and thus
highly reliable directory with both human and machine-readable (eg LDAP)
interfaces. Given all this, it would be sensible to can HeSA and invest
the foregoing national HPI/PKI/directory instead (with a change-over
process from HeSA certificates, of course). I know that authentication
and secure messaging are identified as a "cornerstone" by NeHTA, but
they both go hand-in-hand with directories of health providers. I'll
weep if I see yet another proposal for a healthcare provider directory
which does not make primary provision for PKI keys, certificates and
other authentication mechanisms (and not as an afterthought, to be added
down-the-track).
Tim C
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