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Draft HealthConnect Business Architecture consultation June 2002

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					                      Draft HealthConnect Business Architecture consultation June 2002
                                  Submission #25 (Merck Sharp & Dohme)



                       Helen Leonard
    Your Name/s1


    Organisation       Merck Sharp & Dohme (Australia) Pty Ltd
    (if applicable)

                       Phone                                  Email

       Contact
                       Address
       Details2



       Type of         Organisational Response                 X
                                                                           Please cross one box only
      response         Personal Response
                       Full Publication3                       X
     Publication
                       Anonymous Publication4                              Please cross one box only
      Consent
                       No Publication5




1
    PRIVACY NOTICE
The information provided by you on this form will be used by the HealthConnect Program Office to further develop
the Business Architecture documentation which describes the business processes and requirements for
HealthConnect. The collection of this information is not required by law, and is provided by you on a purely
voluntary basis. The information provided by you on this form may be published on the HealthConnect website
and be accessed by the public, unless you specify otherwise (see 'Publication Consent' box above). Where you
do not consent to that information being published on the HealthConnect website, it may still be used and
disclosed within the HealthConnect Program Office, including external consultants employed by the Program
Office, for the purpose of developing the Business Architecture documentation.
2
  You are not required to provide your contact details, however, if provided it may be used by the HealthConnect
Program Office if clarification of any comments you make is required. Your contact details will not be made public
(irrespective of the level of publication consent indicated).
3
  By giving your consent to Full Publication you agree that your name and organisation, along with any
comments you make can be quoted in full or in part, and published on the HealthConnect website.
4
  By giving your consent to Anonymous Publication you agree that any comments you make can be quoted in
full or in part, and published on the HealthConnect website. No identifying details (eg. Your name, organisation or
identifying remarks in your comments) will be published.
5
  By indicating a No publication response you are indicating that you do not want any identifying details or your
comments to be quoted or published on the HealthConnect website. Your response will only be distributed within
the HealthConnect Program Office to inform the further development of the Business Architecture.

                    Send Responses to the HealthConnect Program Office
                          by email – healthconnect@health.gov.au ,
        by post - MDP 66, GPO Box 9848, Canberra ACT 2601, or by fax – 02 6271 4343.
                              Please Respond by the 28th of June 2002
                                                                                                      Page 1 of 4
                   Draft HealthConnect Business Architecture consultation June 2002
                               Submission #25 (Merck Sharp & Dohme)


           General Comments on the HealthConnect Business Architecture v0.7
                                       (Attach extra pages if required.)



1. In general, this document provides an excellent foundation and focal point for discussion around
   how to realise the benefits of a national network of health records. It is a significant achievement.

2. The Primary Business Problem (page 17) is not well defined, mixing as it does consumer and
   provider goals and wants. Although these can be in alignment as to the ultimate end, the situational
   context of their interaction with the health system discounts any parity of view. The statement does
   not acknowledge the difference between a consumer and a patient, nor does it admit to the funder
   and administrator stakeholders, whilst it would be widely acknowledged that the last part of the
   statement, “ensuring effective use of the health budget” relates most closely to these two groups. In
   addition, the researchers are totally missing from this statement, even thought they are critical if all
   others are to achieve their goals.
   It is vital that all stakeholders are acknowledged, and that their personal and/or business needs are
   accurately and clearly articulated, and not falsely attributed to another party. Benefits realisation
   will be fundamental to achieving the long term aims of HealthConnect.

3. The Critical Success Factors listed do not appear to be long term, but rather issues to overcome early
   in the life of the project. The project could still fail to achieve success longer term even if all these
   CSF’s are achieved.

4. In addition, the CSF’s do not appear to match back directly to the Goals and Purposes, for example,
   the required buy-in could be achieved but without any impact on improving health delivery, health
   outcomes and patient satisfaction with the health system.

5. A sustainable business model is one of the intended outputs of HealthConnect, however there is
   limited discussion on how this can be achieved. Can taxpayers afford to foot the bill for establishing
   and maintaining HealthConnect nationwide? A new approach to partnership models might need to
   be explored, rather than the more conventional ‘involvement’ and ‘consultation’, as these are
   unlikely to deliver the commitment required.

   The document is based around roles that organisations have traditionally filled. In many cases these
   are changing, and in context of the business model issue above, this approach could impose
   potentially unnecessary and inappropriate limitations.

6. If HealthConnect is to succeed, those involved will need to exhibit complementary and supporting
   behaviours, which in general do not spontaneously generate. Although some of these issues are
   discussed, the organisational, structural and behavioural change management issues seem to be
   significantly underplayed.

7. The document does not seem to have explored the area of medical liability. Does involvement with
   HealthConnect affect this, either positively or adversely?




                  Send Responses to the HealthConnect Program Office
                        by email – healthconnect@health.gov.au ,
      by post - MDP 66, GPO Box 9848, Canberra ACT 2601, or by fax – 02 6271 4343.
                            Please Respond by the 28th of June 2002
                                                                                                Page 2 of 4
                    Draft HealthConnect Business Architecture consultation June 2002
                                Submission #25 (Merck Sharp & Dohme)



8. In a number of fora, there has been much discussion about the level and process of communicating
   and coordinating eHealth initiatives, whether instigated by government or private organisations. The
   general opinion, of those who have had long and involved experience and significant expertise in
   this area, is that this is minimal, ineffective and undervalued.
     In this context the risk mitigation strategy suggested in this document of “on-going collaboration”
     seems both limited and passive.
     There needs to be a concerted and committed effort to address this, which would be likely to reap
     significant benefit in progressing the national agenda. It would enable the true sharing of learnings
     and standards and ensure improved focus of resource and effort for maximum advantage. This
     would also facilitate the process of “sunsetting” projects if necessary.




    Document6,
    Part and/or       Specific Comments on the HealthConnect Business Architecture v0.7
     Section                                      (Attach extra pages if required.)
     number


PART 1

Page 24 Consumer Decision Making
It is acknowledged in the document that providing consumer with a list of their medicines does not
equate to providing them with information about their treatment. As our Medical Information group
knows from years of widespread experience with patients, often this will generate a desire and need to
know more.
However, it must be recognised that many current knowledge bases have been developed with the
healthcare professional in mind, not the consumer. The language, terminology and ease of reading and
understanding is paramount to this meeting the needs of the key participant of HealthConnect.
The pharmaceutical industry has been instrumental in ensuring this need is both recognised and met,
through the work over a number of years developing Consumer Medicine Information.

Page 24 Provider Decision Making
There is some functionality outlined for HealthConnect which has the potential to compete directly with
existing health IT suppliers. This is a serious issue, especially with regard to the sustainability of the
business model, duplication of effort involved and confusion caused to the intended user base.



6
 ie Please identify which document, ie Overview or Main Business Architecture, and which part and section of the
document you are referring to when making specific comments.
                   Send Responses to the HealthConnect Program Office
                         by email – healthconnect@health.gov.au ,
       by post - MDP 66, GPO Box 9848, Canberra ACT 2601, or by fax – 02 6271 4343.
                             Please Respond by the 28th of June 2002
                                                                                                    Page 3 of 4
                   Draft HealthConnect Business Architecture consultation June 2002
                               Submission #25 (Merck Sharp & Dohme)



PART 2

D 3.1, 2nd bullet point Page 68
There seems to be an assumption that HealthConnect will bring about a change in consumer self-
management behaviour (eg. recording self-treatment occurrences). This is likely to require further
thought, discussion and additional supporting strategies.

D 3.1, 2nd bullet point Page 68
Most source systems (ie. GP, pharmacy or hospital) will be able to extract a message to HealthConnect
but many do not have in place a transaction logging capability. This audit trail functionality would
require major infrastructure development of many systems.



ATTACHMENT A

Consumer Consent
Generally, these seems too broad, and are not based on the “need to know” principle that most
consumers currently assume or implicitly work on. This is not the same clinical context as sensitive or
private data, as discussed in the document, but is a privacy belief that consumers do have.
That is, people do choose which information they disclose to various providers, and not always due to
the sensitive nature of the information. For example it is not necessary for a dermatologist to know that
a person has had a hysterectomy. The patient may not consider this information highly sensitive but
may still have no desire to have this disclosed to parties who don’t need to know.




                  Send Responses to the HealthConnect Program Office
                        by email – healthconnect@health.gov.au ,
      by post - MDP 66, GPO Box 9848, Canberra ACT 2601, or by fax – 02 6271 4343.
                            Please Respond by the 28th of June 2002
                                                                                              Page 4 of 4

				
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