Adoption of the HI Service will increase as health services incrementally gain access to new e-Health programs that depend on integration with the Service, such as the PCEHR system. The success of this will be dependent on the effective incorporation of the major change management considerations for Healthcare Identifiers in the change and adoption strategies of other e-Health programs. Adoption will also be influenced by the degree to which there is tight integration between the HI Service and the other clinical systems within healthcare services. All systems supporting clinical care, including the HI Service, need to operate seamlessly end to end to minimise the business impacts in time poor clinical environments. From a policy perspective there is a need to standardise requirements for data maintenance, privacy, security, access and use.
The Review found that there are disjoints between the Healthcare Identifiers system functionality and the way business processes and clinical systems currently work that is a barrier to adoption and use. These differences are complicated, and to an extent driven, by variations in State and Commonwealth legislation that also create inconsistencies between established local policies and new policies that are required to support the use of the HI Service. Again, it makes it difficult for healthcare services to drive adoption if there are separate processes and policies for the HI Service to those applying to other clinical systems.
The major issues identified in relation to the operation of the HI Service that are seen as barriers to adoption were in the areas of management of change requests, prioritisation and content of releases, complexity of establishing organisational seed and network structures, access to HPI-Is and assignment of IHIs for individuals that do not return a result when a search is conducted. As additional programs such as the PCEHR system are being implemented there are increasing issues arising from the parallel operation, support, policy frameworks and governance of these programs. This environment will become even more complex as additional programs come online. Maintaining the separation between these programs is likely to increase the challenges for all organisations participating in e-Health.
In summary, the major barriers identified in the consultation for this Review included the following:
- Complex registration processes for healthcare organisations that are perceived by providers to not adequately leverage existing relationships with these organisations, resulting in duplication of effort for organisations. Although it is noted that there has been an improvement in these processes and Evidence of Identity (EOI) is not required for a “known customer”, there are opportunities to further streamline or clarify some processes for providers. For example to register a seed organisation the Responsible Officer has to prove their authority. The Application To Register a Seed Organisation form on the HI Service website states that “To establish that the Responsible Officer is authorised to act on behalf of the Seed Organisation one of the following documents must be submitted in support of this application: An ASIC Company search displaying the Responsible Officer as Director....). Rather than requiring healthcare services to do this process, the company search can also be performed by DHS. While these searches are performed by DHS, the written instructions on the application form lead providers to assume they need to do this search prior to applying which is seen as an unnecessary overhead.
- Difficulties accessing identifiers for Providers and a lack of clear processes for individuals for whom an IHI cannot be found (processes for newborns, provisional and unverified IHIs) that impacts use in a clinical setting (section 3.1 and 3.2).
- Challenges with establishing appropriate seed and network structures (section 3.4.2).
- The opt in basis and low participation rates in the HPD that is impacting utility for downstream systems (section 3.2 and 4.7).
- Restrictions on disclosure of identifiers and identifying information impacting utility in health services (section 3.2).
- Parallel and fragmented governance, support and implementation processes for Healthcare Identifiers and other dependent programs (section 2.1 and section 2.5).
- Functional constraints that limit the use of IHIs being adopted for communication purposes within jurisdictions (section 5.6).
Although there are issues that are having an impact on adoption and use, the majority of these can be addressed through refinement of business processes across the organisations participating in the HI Service (both from a service delivery and end user perspective) and through a focus on communication and change management activities. The recommended changes to the Act and HI Service functionality, infrastructure and support are intended to address the issues highlighted by stakeholders in the course of this Review and enhance the useability of the Service for health services as the e-Health environment expands in scope and complexity. Appendix 5 recommends additional operational actions to address issues raised by stakeholders to further streamline the operation of the Service.