Toward better implementation: Australia's My Health Record

Abstract

A well implemented and fully utilised electronic health record system should strengthen a health system by improving quality and safety, ensuring continuity of care and improved health outcomes as well as reducing waste and inefficiency in the health system. Australia chose to pursue a personally controlled electronic health record (PCEHR) system following a 2009 recommendation from the National Health and Hospital Reform Commission. A PCEHR is a special class of electronic personal health record where a consumer controls his or her record content and record access, which means only nominated health practitioners are able to access nominated information in the record. Due to a lack of uptake and utilisation, in 2015 the Australian Government announced a system overhaul, which included rebranding the PCEHR to My Health Record and moving from an opt‐in to an opt‐out system. While the overhaul attempts to address the key problems identified in a 2013 external review of the PCEHR, a number of experts have flagged concerns with the new My Health Record, which should be addressed prior to implementation. The following are three key and ongoing implementation concerns along with recommended actions to overcome these concerns. Lack of registered users, system use and clinical utility The following actions are recommended to accelerate achievement of My Health Record critical mass, system use and clinical utility: comprehensive system security and privacy safeguard review with subsequent action plan to address concerns prior to opt‐out pilots, followed by proactive messaging to consumers and providers that technical security has been dealt with in the design of the record comprehensive communications and engagement strategy with targeted and sustained consumer‐ and provider‐specific education and registration activities leveraging consumer groups, peak bodies, professional colleges and software distributors comprehensive and best‐practice provider training based on an iterative process to develop training modules and the training platform with stakeholders registration incentives for both consumers and practitioners such as an increased Medicare rebate for system use as part of clinical activity technological and business support, including financial incentives to service providers nudging uptake and use software default settings linked into the interoperable national health record system flexible and clear policy and technical frameworks that are adaptable to clinical need structural change to the data sharing model where information necessary to the current treatment of a consumer is shared among the care team Opt‐in versus opt‐out registration The following actions are recommended to ensure a smooth transition from an opt‐in to an opt‐out consumer controlled electronic health record with evidence‐based privacy and security protocols: comprehensive system security and privacy safeguard review of the current architecture evaluated against a repurposed opt‐out functionality, which includes both threat and risk assessments as well as privacy impact assessments action plan stemming from the review to implement a mix of technology, policy and process mechanisms aimed at strengthening security and privacy controls—to be completed prior to My Health Record’s opt‐out trials public education campaign demonstrating system security and privacy safeguards engagement with software developers and distributors to ensure software compliance with necessary system changes and to ensure ongoing system interoperability update current provider training due to opt‐out transition and work with the sector to develop and rollout revised modules Governance The following actions are recommended to ensure best practice and inclusive My Health Record governance arrangements: key national and regional stakeholders as well as consumers should be part of My Health Record’s governance arrangements in order to secure buy‐in from the health and community sectors and key consumer groups consideration should be given to the following building blocks for effective governance: strong leadership, culture and communication appropriate governance committee structures clear accountability mechanisms working effectively across organisational boundaries comprehensive risk management and compliance systems strategic planning, performance monitoring and evaluation flexible and evolving principles‐based systems the Council of Australian Governments’ Standing Council on Health should play a leadership role to ensure these effective governance building blocks become more than aspirational