Draft Concept of Operations Feedback Analysis Report
4.3 General design suggestions
| Total submissions containing this theme | Breakdown of submissions containing this theme by group |
|---|---|
| 11.2% |  |
4.3.1 Description
Design suggestions for the PCEHR System were a common theme. A number of the submissions requested design clarification of detail regarding the nominated provider, Shared Health Summaries and conformant repositories.4.3.2 Key points
1. Nominated provider and Shared Health Summary- Clarification was sought regarding how nominated providers will be regulated and controlled by the Australian Government, including whether there will be definitive criteria to become a nominated provider
- Concerns were raised that if the nominated provider pool includes self identified skill sets then the information in the Shared Health Summary may become unreliable
- Several questions were raised regarding the details of the architecture of the conformant repositories
- Questions were raised regarding the performance, responsiveness and reliability of having multiple conformant repositories located across Australia
- Questions were raised regarding the potential risk of having a PCEHR or Shared Health Summary located on another conformant repository which may be unreachable due to system or network error the safety and legal risks of this situation were highlighted
- Some responses listed general suggestions or requests for clarification of design details listed in the ConOps
4.3.3 PCEHR program position
Based on the feedback received during the public consultation process the following changes have been applied to the ConOps:Nominated Provider – Some clarification to the role of nominated provider and the Shared Health Summary have been provided. The criteria required to fulfil for the role of a nominated provider have been stated, such that: a medical practitioner; an Aboriginal health worker; or a registered nurse would be best placed to moderate the shared health summary.
Regulation of Conformant Repositories – The model around regulation of conformant repositories has been reviewed and input has been sought via the Legislation Issues Paper on a range of issues including: the requirements to be a conformant repository provider; archiving and disposal of information; and the safe management of information held within a conformant repository.
Support for individuals and healthcare providers when registering – An administration portal and contact management service have been added to the system to aid service and support agents, authorised registration agents and call centre agents to better support individuals and healthcare providers with their access to the PCEHR System. This will provide a common PCEHR System view of requests raised by participants across multiple channels, including a call centre, portals and via physical locations (e.g. Medicare branded shop fronts, healthcare organisations which support assisted registration), and allow for these requests to be handled in a common, integrated manner. It will provide consumers of the system with a way to monitor and track each request that they raise , and to be informed about the expected response time for resolution of the issue.
Improved ease of use – The change history view has been removed and the index view now includes an option to find amended clinical documents. This will improve ease of use by simplifying the ways that information relating to a PCEHR can be viewed.
Training on the role and responsibilities of a Nominated Provider will be provided as part of the change and adoption workstream, so that potential Nominated Providers are aware of the responsibilities and requirements associated with the role. The requirement for a potential Nominated Provider to attest to their eligibility, in accordance with the criteria outlined above, prior to submitting a Shared Health Summary may be a compliance requirement for software vendors who provide such functionality.
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