" Background:
The Department
of Health and Ageing has initiated the development of two potentially
important Health Industry IT projects:
BMMS
- The Better Medication Management System ( now known
as MediConnect) is a system designed
to allow electronic prescriptions to be securely transmitted and
stored in a central repository and also enable pharmacists to
download prescriptions via the Internet. The central tenet of
this functionality is that patient prescription history will be
stored in a secure central repository to allow professional providers
(Medical Practitioners and Pharmacists) access to consolidated
prescription/dispensed item details to assist with better patient
outcomes and quality use of medicines.
HealthConnect
-
Is a system designed to deliver the nirvana of IT systems for
the Health Industry i.e. an ELECTRONIC HEALTH RECORD. Ultimately
this system will allow professional providers to view (via Event
Summaries) consolidated patient history details. This is a massive
undertaking and will take many years of R & D before any real
results can be achieved.
Following please find an abbreviated list of issues that need
to be canvassed and are not exhaustive.
IT
Development Projects:
It is a not
so well known or understood fact that 90% of IT development projects
FAIL, either totally or in part. The reasons for either TOTAL
or PARTIAL failure include:
* Change in
market requirements.
* Insurmountable technical issues.
* Cost overrun.
* Completion time blow-out.
* Failure of the Systems Integration Design.
* Specifications not met.
* End user dissatisfaction with system, etc.
.
For details of the 16 different Critical Project Management issues
go to: http://www.spmn.com/16CSP.html#risk
The size of
a project does not guarantee success and there are many examples
of huge projects totally failing eg. Westpac Bank about 12 years
ago spent $250 million (over 3 years) in an attempt to rewrite
their banking system. This project was a TOTAL failure.
Following
is an example of a recent partial failure due to a massive cost
blow-out:
NAB management
software system costs blow-out: Report March 22 2002
National Australia
Bank Ltd has been hit by another cost blow-out on a new management
software system that is now expected to top $800 million, double
the
original estimates, The Australian Financial Review reports.
A further
$200 million in extra costs has been linked to execution difficulties
and consultancy agreements and follows trouble earlier this year
when the estimated cost
climbed $200 million, the newspaper reported.
The system
is meant to provide full integration of NAB's global technology
operations.
On Tuesday,
the newspaper said a newly created review team presented the $800
million estimate to the bank's board, which is believed to have
given management approval to press ahead with implementation despite
internal concerns that costs might escalate further.
On Wednesday, a bank spokesman declined to respond to questions
about Tuesday's meeting, it said.
This story was found at: http://www.smh.com.au/articles/2002/03/22/1016758525858.html
In November
2002 another TOTAL failure was announced as follows:
Sydney Water
is expected to take legal action to recover some of the costs
associated with its $70.2 million customer information and billing
system - but just who will carry the can for the aborted project
remains unclear. Earlier this month, Sydney Water announced it
had terminated the CIBS contract held by PricewaterhouseCoopers.
Full story at following link: http://afr.com/it/2002/11/12/FFX32RF8D8D.html
Risk
Analysis:
There should
be awareness, that on any independent risk analysis of the HealthConnect
and BMMS (MediConnect) projects,
there is huge potential for catastrophic failure. I am not aware
of any normal Project Management Systems (which includes risk
analysis techniques) being utilised in the planning process of
these very expensive projects. The importance of the cost of these
projects (est. $150 mill. over 5 years) versus the cost benefits
also need to be scrutinised.
The major
risk factor here is that it is an opt-in system by the professional
providers and the patients. Because of this, the effectiveness
(the ability to have recorded a meaningful i.e. complete patient
record) is very small indeed. It depends on the patient who has
opted in presenting to GP, pharmacist, and hospital providers
who have all opted in.
At this point
in time there are no incentives to ensure a significant number
of patients and professional providers opt-in. For this issue
to be evaluated, a survey of patients and professional providers
should be completed to gauge the intentions of the protagonists.
Without this information the projects will only discover the "take
up" after the fact.
My gut feel
is that one could expect that around 15% of patients, GPs' and
Pharmacists might opt in. If this is the case then it does not
augur well for success. If 15% of patients present to GPs' and
Pharmacists, of whom only 15% have opted in, then < 1% of the
population will have a meaningful (i.e. complete) health record
accessible.
How could this justify the expenditure of $150 million?
Even if 70% of patients and professional providers opt-in, the
end result will be that only 35% of health records will be complete,
unless patients are streamed to participating prof. providers.
In order to
obtain support from the professional providers, any systems design
must be such that there is minimum interaction necessary by the
providers. Any system interaction that would impact on the providers'
ability to process their heavy workload will be a huge disincentive
to opt in.
Dependencies of the projects include:
ELECTRONIC
HEALTH RECORD
Currently
there is no internationally recognised Electronic Health Record
standard available. The International GEHR (Good Electronic Health
Record) project (the only non-proprietary "Open" system)
has yet to agree on a standard.
For information regarding the complexity of the subject, go to:
http://www.gehr.org/
UNIQUE
PATIENT IDENTIFIER
The BMMS (MediConnect)
project is committed to using the Medicare Number as the UPI (Unique
Patient Identifier) and as BMMS (MediConnect)
is really a sub set of the HealthConnect project it is important
that they share a common UPI. This apparently is not the case,
with HealthConnect seemingly committed to using a NSW developed
UPI a component of which will be the Medicare Number. There is
a requirement for these (BMMS (MediConnect)
& HealthConnect) projects to harmonise (co-ordinate) the functionality
of the applications they intend to deliver. Ultimately the two
projects should be merged.
COMMUNICATIONS
INFRASTRUCTURE
The Department
of Health and Ageing (DoHA) and Health Insurance Commission (HIC)have
abdicated any responsibility for provision of a standard communications
platform, instead suggesting that all the Professional providers
(GPs'/Pharmacists etc.) arrange to have their personal computers
connected to the internet via an Internet Service Provider (ISP)
of their choice. This is a recipe for disaster.
The on-line GP applications (ANS /BMMS (MediConnect)
etc.) depend on synchronous communications, requiring response
times of less than 5 seconds. With no Service Level Agreement
(SLA) being available from most ISPs' in Australia and no centralised
network administration/support and with low bandwidth delivery
of modems, any communications consultant will advise that the
system will not function efficiently.
UNIFIED
PRODUCT CODE
Both systems
(especially the BMMS-MediConnect)
require a health industry UPC (unified product code) standard.
The MCCA project is the driver of this standard (EAN International
standard) and unfortunately, due to the intransigence of the product
manufacturers and Therapeutic Goods Administration (TGA) unwillingness
to co-operate, it is not possible to estimate when this will become
a reality. i.e. the electronic prescription will not be able to
be transmitted with confidence of the integrity of the prescribed
drug without there being a standard product code (The BMMS/MediConnect
field tests may have to be implemented using the existing Pharmaceutical
Benefits Scheme (PBS) codes, which is only a short term solution).
To further
complicate matters it now appears that some product manufacturers
are backing the introduction of the opposition HIBCC product coding
system into Australia.
MEDICARE
CARD SYSTEM
The Medicare
card system, which provides the Patient identifier for the BMMS/MediConnect
is a failed system. At one stage it was established that 23 million
cards had been issued for an Australian population of approx.
19 million. The Medicare card system needs to be redesigned. The
Health Insurance Commission (HIC) however are reluctant to entertain
this for various reasons (cost, necessary legislative changes,
spectre of the "Australia Card", resistance to change
etc.) The Medicare database is demonstrably inaccurate and the
HIC have elicited the assistance of pharmacists in an endeavour
to clean it up by having the pharmacists record the Medicare number
for all PBS dispensed items and check the patients' card against
the HIC Database, utilising the Claims Transmission System to
identify mismatches. This of course only partially addresses the
problems of the system.
DRUG
INTERACTION/ALLERGY CHECKING
Part of the
benefit of the BMMS/MediConnect system
will be to have a central database of all medications prescribed/dispensed
to patients, which would enable drug interactions/allergy checking.
The problem is that BMMS/MediConnect
does not take the opportunity to leverage off this information.
The system specs propose that Drug Interaction/Allergy checking
remains with the individual Clinical Management/Dispensing Systems,
without standards being imposed.
Will the results
of this check form part of the BMMS (MediConnect)/HealthConnect
record?
If so this will result in potentially very large files which will
be difficult to interpret because there is no standard Drug Interaction
database system. Each application system has its' own method of
Drug Interaction reporting and Drug Interaction database. One
might use the method of mild/moderate/severe reactions vs another
using the 1-5 system. One system may report on all reactions or
only moderate and or severe. Using a sample Patient medication
profile it has been discovered that there is little correlation
between the reports generated by the disparate applications.
The result
is it would be impossible to have meaningful aggregation of this
information. There is a need for Govt. (via the National Prescribing
Service (NPS)?) to develop a standard for Drug Interaction/Allergy
reporting together with a common Drug Interaction/Allergy database.
The BMMS (MediConnect) /HealthConnect
projects need to address this issue.
Because drugs
can be combination products, an allergy checking system would
need to be able to distinguish the components of the product e.g.
Septrin (Trimethoprim & Sulphamethoxazole) with either of
the components having potential for an allergic reaction.
This is another
reason for the importance of the MCCA project. The EAN record
has 43 fields, one of which is populated with the active ingredients
of the proprietary product. The EAN record could assist in providing
a more efficient way of building an allergy checking system.
The onus for Drug Interaction/Allergy checking usually defaults
to the pharmacist who then must report any issues to the prescribing
doctor, which is bad systems (procedural) design. With a centralised
checking system, the doctor will be alerted at the time of prescribing,
thus being able to immediately adjust the course of treatment.
MSIA
The Medical
and Pharmaceutical software providers (represented by the Medical
Software Industry Association) has determined that any software
development that is specified by government and is for the sole
purpose of assisting government projects without enhancing functionality
to the professional providers, should be funded by government.
A formal Agreement for funding to be provided to the MSIA members
has yet to be finalised.
Time-lines will continue to blow out as none of the software providers
have written one line of code.
Worse still, because the software providers have limited resources
with an ongoing commitment for development for their clientele,
any additional development work will have to be scheduled accordingly.
HL7
There are
still issues regarding HL7, eg. the BMMS/MediConnect
non-compliance with the E-Prescription HL7 standard. Is there
really a need for HL7?
Is there a more efficient less complex method of file formatting?
Why must BMMS/MediConnect use HL7
when the MedClaim system uses UNEDIFACT.
The situation in Australia is fairly unique because there is effectively
only one HMO (HIC).
Electronic transmission of data is therefore from one to many
or vice versa.
Use of an XML standard should be sufficient for the BMMS/MediConnect
project and would be less complex to implement.
PKI
As yet there
is no example of any large scale implementation of PKI (Public
Key Infrastructure) similar to the BMMS (MediConnect)/HealthConnect
projects anywhere in the world. Obtaining a CA (Certification
Authority) is currently a lengthy procedure that could be a disincentive
for Professional Providers to opt in.
PROVIDER
DIRECTORIES, this important administration facility
required to support PKI still has many issues yet to be resolved.
There is widespread
support in the IT community for the notion that the use of the
PKI standard is an "overkill" solution.
For a US Govt
(General Accounting Office). report regarding problems relating
to PKI go to: http://www.gao.gov/new.items/d01277.pdf).
and for problems discovered by a commercial user: http://www.computerworld.com.au/IDG2.NSF/a/00081A0A?OpenDocument&n=e&c=Sc
The mandatory
use of PKI /HL7 and perhaps XML (HL7 Ver 3) (for info on performance
problems faced by XML: http://www.zdnet.com.au/itmanager/technology/story/0,2000029587,20264223,00.htm)
comes with significant processing overheads requiring a large
% of professional sites to upgrade their PCs. The use of the designated
personal security token (for GPs') can only be used on later model
PCs that have a USB (Universal Serial Bus) installed.
WHO PAYS FOR SYSTEM UPGRADES, WHO INSTALLS THE UPGRADED SYTEMS
AND TO WHAT STANDARD?
OTHER ISSUES
Privacy and
other legal/procedural aspects involving the projects, have yet
to be fully addressed or tested.
FIELD
TRIALS
Field trials
for BMMS/MediConnect are scheduled
to begin in the first quarter 2003. Huge resources from paid government
consultants are working in consultation with voluntary (including
unpaid expenses) industry representatives/software providers,
who have been co-opted to help on a large number of committees.
From personal observation, much advice given by these industry
committee workers has had a variable reception (i.e. advice is
not listened to) by the government project development groups.
In particular
it should be noted that the IT software developers were not consulted
before the Systems Integration Designs were developed.
They should have been consulted to examine if there were options
for more efficient ways of delivering the functional requirements
of the projects.
As it stands they have been invited (sometimes reluctantly, in
the case of the DG-BMMS/MediConnect)
to join committees, to rubber stamp directions.
SUMMARY
In summary
I believe that the cart has been put before the horse.
The projects need to be postponed until such time as all the dependant
issues required for the projects to operate successfully are addressed.
Certainly some of the funding should be redirected to the critical
dependency areas, some of which suffer from inadequate funding/resources.
ALTERNATIVE SYSTEMS INTEGRATION DESIGN
There are
alternative systems integration designs for BMMS/MediConnect
that could:
* Achieve
greater procedural efficiency, which in turn would ensure a larger
number of Professional Providers opt-in.
* Assist with overcoming some of the dependency issues.
* Achieve a faster development time-line.
* Reduce the cost of delivery of the systems.
It is not
the purpose of this document to explore these options rather than
to alert people to the fact that there are other viable options.
Information to support this issue is available on request."
Editor's
Note: The issues raised above are extremely important and any
person who would like to comment either in support or from an
alternative perspective, I would be happy to hear from you.
|