21 November, 2017
With affordable, universal coverage and access, healthcare in Australia is amongst the world’s most advanced. Second only to the UK according to the Commonwealth Fund’s International Health Policy Survey, Australia’s health system ranks best on efficiency and healthcare outcomes1. Yet at home, many Australians feel that healthcare should be more affordable and more efficient, citing high out-of-pocket costs and long hospital wait times as flaws in the current system2.
Australia’s notable lack of technology in healthcare is a contributing factor to increased costs and lower standards of care. The industry is heavily regulated and expensive to innovate in, so the uptake of digital services has been slow and fragmented. Acknowledging the need for digital innovation, the Council of Australian Governments has recently endorsed the Australian Digital Health Agency’s (the ‘Agency’) Strategy3. The Strategy is the product of consultation with consumers and healthcare industry professionals, and aims to deliver coordinated health information through digital channels to tailor and improve the quality of Australian healthcare. The Agency’s CEO Tim Kelsey stressed the need for this initiative, stating that Australia is facing rapidly rising demand for services, and that harnessing the power of technology will support high quality, sustainable healthcare for all Australians4.
The Strategy
In July 2016, Australia’s State and Federal Governments established the Agency as the body responsible for evolving Australia’s digital health capabilities by developing a plan to integrate digital information into the Australian health system. In developing the Strategy, the Agency conducted extensive research and consultations across the healthcare industry, seeking the input of patients, carers, innovators, organisations and industry professionals. The Strategy also builds upon existing leadership in digital healthcare by industry and Government, with the aim of integrating existing digital health initiatives and unifying future investment in digital health infrastructure. The Strategy proposes that the following seven priority outcomes be achieved by 2022:
Health information that is available whenever and wherever it is needed
Key to this strategic outcome is the rollout of My Health Record, a secure online summary of Australian patients’ health information, accessible by the patient or a healthcare provider at any time online and through mobile apps. Among other benefits, it is hoped that My Health Record will improve the coordination of care for people with chronic conditions as well as reduce the instances of adverse drug reactions by supporting more effective medication management.
More than five million Australians have already signed up for My Health Record on an opt-in basis. The Strategy plans to have every Australian utilising My Health Record by the end of 2018 by transitioning to an opt-out program of participation5. It’s intended that by 2022, this health information will be accessible to all Australian healthcare providers.
Health information that can be exchanged securely
The Strategy aims to deliver secure digital channels to deliver information between clinicians by 2022. The development of secure digital channels would end reliance on paper based correspondence, allowing patient information to be shared securely in real time between hospitals and healthcare professionals to improve the continuity and coordination of treatment6. Although Australia’s current health system does utilise established methods of secure messaging, with no nationally consistent approach these methods are not compatible and still hinder effective and timely communication between healthcare providers. For patients, this means delayed and disjointed treatment which can lead to poorer health outcomes7. Professional bodies and health services have identified this lack of coordination in secure messaging as the Strategy’s most pressing priority area8.
High quality data with a commonly understood meaning that can be used with confidence
This strategic outcome recognises that it is only where clinical data can be easily exchanged, understood and applied that high quality, sustainable healthcare can be achieved. Accordingly, the Strategy aims to ensure health data is collected in standard ways so as to allow for common understandings across different health service providers. The Strategy contemplates that by the end of 2018, a public consultation on draft interoperability standards will inform an agreed vision and framework for implementing common standards across all public and private healthcare services in Australia9.
Better availability and access to prescriptions and medicines information
This priority aims to deliver better management of medicines information by providing up to date and comprehensive medication histories for patients. The Strategy envisages that by the end of 2018, all consumers and their healthcare providers will be able to access the full history of their prescribed and dispensed medications as a function of their My Health Record online10. This will see greater continuity and better access to the correct medications, even where a consumer switches to a new health provider. By 2022, the aim is for prescribers and pharmacists to have access to electronic prescribing and dispensing so as to enable all Australians to digitally request all medications online.
Digitally enabled models of care that improve accessibility, quality, safety and efficiency
Underlying the entire Strategy is the aim that investment in Australia’s digital health system will develop new models of healthcare that can be tested and scaled up to benefit all Australians. As part of this focus, priority health reform areas such as telehealth and end of life care will utilise ‘test bed’ projects that measure and prove the benefits of digital technologies in real-world environments before any innovations or learnings are rolled out nationally11.
A workforce confidently using digital health technologies to deliver health and care
In implementing new digital technologies, the Strategy also makes a commitment to training and supporting healthcare professionals in delivering digital services. The Agency will collaborate with Government, care providers and workforce educators to ensure that by 2022 all healthcare professionals will have the resources and support to feel confident in using digital services.
A thriving digital health industry delivering world class innovation
The last strategic priority focusses on the future for innovation in Australia’s digital health industry. The Strategy proposes initiatives that will encourage entrepreneurs and program developers to expand on existing health services and accredited health app offerings.
The Agency acknowledges that the Australian Government plays a critical role in providing a regulatory environment that fosters innovation and states that further action to boost investment in digital health product development and commercialisation is needed for this goal to be realised.
Cyber security and privacy concerns
Whilst the Agency is confident that the Strategy will see health information exchanged securely, others are not. Concerns have been raised over the cyber security and privacy implications of storing and transmitting the personal health data of Australians.
Health data is one of the most sensitive categories of personal information and as a result attracts a higher degree of regulatory oversight in accordance with the Australian Privacy Principles12 and bespoke state-based health records laws.
To secure health data in light of the security issues occasioned by digital health services, the Agency has established the Digital Health Cyber Security Centre (‘DHCSC’) to monitor and assess cyber threats and facilitate regular reviews of information security13.
The DHCSC’s security plan involves leveraging the expertise of cyber security organisations across the Government and private sectors, in order to devise mechanisms to prevent and manage cyber risks posed by the use of digital health services14.
Comments from the industry reflect concern over the Strategy’s lack of concrete detail on how sensitive medical records will be secured. Commentators stress that information security will be particularly difficult to achieve when numerous apps and platforms are used by different healthcare providers to access the same systems15. Further, the Government’s previous issues concerning the management of sensitive information does not inspire confidence, with industry figures citing the incident of Medicare card details for sale on the dark web as one example16.
Looking forward
Despite these concerns, the Strategy is a commendable step in modernising Australia’s approach to healthcare.
There are obvious benefits to utilising digital health services including a reduction in unnecessary hospital admissions and fewer errors in medicines administration. Whether these benefits can be realised will however depend on these initiatives being successfully implemented.
The Strategy’s success relies upon Australia having the frameworks in place for sharing health data securely. Efforts to modernise Australia’s approach to data management are underway following the Productivity Commission’s recommendations for an overhaul of Australia’s data policy framework17. Whether the Australian Government follows through with these recommendations remains to be seen. Until then, we must wait to hear how the Agency intends to roll out its Digital Health Strategy within Australia’s existing legal framework.
1 The Commonwealth Fund, Mirror, Mirror 2017: International Comparison Reflects Flaws and Opportunities for Better US Health Care (July 2017), http://www.commonwealthfund.org/~/media/files/publications/fund-report/2017/jul/schneider_mirror_mirror_2017.pdf
2 S. Duckett, ‘Australia's health system is enviable, but there's room for improvement,’ The Conversation, 22 September 2017, https://theconversation.com/australiashealth-system-is-enviable-but-theresroom-for-improvement-81332
3 Australian Digital Health Agency, ‘Safe, seamless and secure: evolving health and care to meet the needs of modern Australia – Australia’s National Digital Health Strategy’ (2017).
4 Australian Digital Health Agency, ‘Health Ministers approve Australia's National Digital Health Agency,’ https://www.digitalhealth.gov.au/news-and-events/news/health-ministers-approve-australias-national-digital-health-strategy
5 The Strategy, above n 3, 21.
6 Ibid.
7 Australian Digital Health Agency, ‘Secure Messaging Problem Statement’ (2016) Sydney.
8 The Strategy, above n 3, 25.
9 The Strategy, above n 3, 28.
10 The Strategy, above n 3, 34.
11 The Strategy, above n 3, 38.
12 Schedule 1, Privacy Act 1988 (Cth).
13 Australian Digital Health Agency, ‘Digital Health Cyber Security Centre,’ https://digital-health-cyber-security-centre
14 Ibid.
15 Lynne Minion, ‘Critics voice concerns about a national digital health strategy lacking detail,’ Healthcare IT News, 8 August 2017, http://www.healthcareit.com.au/article/critics-voice-concerns-about-nationaldigital-health-strategy-lacking-detail
16 Lynne Minion, ‘Critics voice concerns about a national digital health strategy lacking detail’ Healthcare IT News, 8 August 2017, http://www.healthcareit.com.au/article/ critics-voice-concerns-about-nationaldigital-health-strategy-lacking-detail
17 Productivity Commission, Data Availability and Use, Final Report (2017).
For further information, please contact:
Toby Patten, Partner, Baker McKenzie
toby.patten@bakermckenzie.com
