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July 7, 2015
PCEHR/ HI Discussion Paper Feedback
Department of Health
Email: [email protected]
Dear Sir/Madam,
Re: Legislation Discussion Paper
Thank you for the opportunity to respond to the Legislation Discussion Paper concerning Electronic
Health Records and Healthcare Identifiers. The issues being addressed are important and we
commend you on the thoroughness of the paper.
National Home Doctor Service
National Home Doctor Service (NHDS) is Australia’s largest medical deputising service, playing a critical
role in the delivery of after hours health care in Australia.
In the last twelve months we arranged around one million after hours visits to patients at home and in
aged care facilities across eight cities in Australia. We also commenced operations in Canberra and
extended our service into smaller regional centres where we provide the electronic management
systems, call centre handling and billings processes for groups of local doctors who wish to engage in
after hours practice.
Medical Deputising represents only a small proportion of the primary care services delivered in
Australia, but is important in ensuring primary care access right through the after hours period,
especially for vulnerable groups such as the elderly, infants and people who lack access to transport.
The after hours period — when daytime GP practices are closed — represents approximately 70% of
the hours in the week. We do not provide routine care or respond to emergencies. We respond to
urgent, episodic care requirements. In doing so, we help reduce unnecessary emergency department
presentations and help patients with chronic conditions address their health issues at the earliest
possible opportunity. In essence we deliver ‘the right care, in the right place at the right time’.
Unlike the other options available during the after hours period – Emergency Departments and
extended hours clinics — medical deputising services ensure effective coordination and connection
between three key parties during the after hours period; the patient, their regular GP and the after
hours attending doctor.
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We provide the services to ensure that a) patients’ urgent, episodic health care needs are met, b)
doctors can efficiently practice medicine in the after hours period, and c) GPs can maintain continuity
of care with their patients.
Importance of Accurate Records in After Hours Primary Care
We are committed to ensuring continuity of care is maintained when we arrange for one of our
doctors to visit a patient. We have formal deputising arrangements in place with approximately 2000
practices representing 7000 GP’s across Australia. We support continuity of care for all patients and
work actively in the community to avoid fragmentation of healthcare by:
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Allowing subscribing GPs to issue specific patient instructions which are stored in our system
and transmitted to the after hours visiting doctor so that they are aware of unique conditions
or preferences of the GP
Providing a secure clinical report back to the regular GP for all patients the following day
outlining the diagnosis, course of treatment prescribed and follow up as may be required by
the GP
Contacting the regular GP if we observe conditions or a pattern of use that would benefit from
the GP intervening, and
Encouraging patients without a regular GP (a growing trend) to find one and directing them to
GP practices that we know are accepting new patients.
Due to the nature of after hours care, access to relevant and timely health records is particularly
important. We see patients at home and in aged care facilities seeking episodic care in the after hours
period . As such our relationship with patients is not ongoing but episodic and irregular. On average
we see patients slightly more than once per year. This means we are unlikely to have up to date
records for many of the patients our doctors visit.
Access to accurate and up to date patient information would significantly assist our doctors to address
the needs of the patients they see in the after hours period — especially those with chronic conditions
and comorbidities or those who may present with conditions that might pose a safety risk to our
doctors. Our doctors advise that the single biggest benefit of access to comprehensive patient records
would come from having access to an up to date medications list. This information is valuable in
making good decisions regarding medications and supports doctors to take more accurate medical
histories by alerting the visiting doctor to possible conditions and even allergies. This would greatly
assist the doctor to treat an urgent episodic issue in the patient’s home.
We work closely with our subscribing GPs to overcome this barrier. Our patient management system
provides the capacity for GPs to issue us with specific instructions or information concerning any of
their patients. These will typically cover such issues as:
 Specific instructions concerning palliative care
 Medication instructions where unusual conditions need to be highlighted
 Circumstances where the GP would prefer to be contacted, for example for a verification of
death of one of their patients, even in the unsociable hours
 Drug seeking behaviour that a patient may have, and
 Other patient-specific instructions that the regular GP wants our doctors to be aware of.
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Our system ensures that the after hours doctors see this information on their laptop or iPad prior to
beginning a consultation with a patient. Given the episodic nature of our relationship with these
patients, the instructions are very important and we encourage our subscribing GPs to make use of
this function. To this extent we have implemented a ‘light’ (but highly valuable) version of electronic
patient information moving between the patient’s regular GP and our doctors.
As also mentioned above, we provide a secure clinical report to the regular GP before the
commencement of the next working day. The clinical report outlines the symptoms, diagnosis and
treatment prescribed by the after hours doctor and indicates if any pathology or radiology was
ordered (this is quite rare).
NHDS has a well developed electronic patient management system that records every stage of the
doctor intervention and is expressly designed to ensure we ‘close the loop’ and ensure the patient’s
medical home remains their local GP. The system captures data from the moment a member of the
public calls NHDS seeking a home visit, to the transmission of patient instructions to the attending
doctor, transmission of his report back to the GP and even management of patient feedback and
follow-ups.
For this reason, NHDS would be interested in the potential to trial wider implementations of e-health
records within the IT environment we have established should the Department of Health wish to do
so.
Comments with Respect to Discussion Paper
Given our experience of the value of electronic records, we support all steps to move towards
increased access to accurate and universal electronic health records. We believe the changes
proposed are clear and represent pragmatic steps in the right direction.
In terms of specific responses to the discussion paper:
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We support the testing of an ‘opt-out’ participation model. There are too many instances in
our healthcare system where inertia is the main barrier to new processes and better
outcomes for patients. We, as health care industry participants, need to actively encourage
the adoption of electronic medical records. We believe the ‘opt-out’ starting point will help
facilitate adoption.
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We encourage all steps such as those set out in the discussion of the Health Identifier that will
provide a means for healthcare providers to more accurately match the right record to the
person being treated. This is critical in any clinical setting but even more important to us given
that our relationship with a patient is by definition episodic and irregular in nature.
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We agree with the need to expand the definition of ‘healthcare’ to include such matters as
palliative care and aged care plans. In addition, the inclusion of information relating to
physical, but also mental or psychological health matters is very relevant to our doctors. Such
information can specifically help our doctors manage potential risks during the home visit.
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We believe the change of name from PCEHR to My Health Record is consistent with a strong
desire to demystify electronic health records and encourage take up. It is a step in the right
direction.
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We appreciate the opportunity to respond to this Discussion Paper and would request being made
aware of future developments. As Australia’s largest provider of after hours home doctor visits we
bring a unique perspective to these matters and look forward to contributing to the work to
implement the national system of electronic health care records.
Kind regards,
Ben Keneally
Dr. Beres Wenck
Chief Executive Officer
Chairman, Clinical Advisory Group