Response 446064152

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Public Pathology Australia

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Review of the My Health Records legislation

Do you have any feedback to provide on the review process or the outline of the My Health Record system?

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Review of the My Health Records legislation

Please provide your feedback in relation to the general themes identified in the consultation paper on the operation of the My Health Record system.

Please leave your comments below
Public Pathology Australia remains strongly in support of the MHR and its stated objectives.
There has been access to My Health Record (MHR) by clinicians in public hospitals and use by consumers. However, low rates of uploading clinical information by GPs, other specialists and some pathology providers has impacted on the ability to achieve the stated objectives. This is particularly the case in relation to trying to reduce duplication of testing.
Currently, a number of pathology providers are not uploading pathology reports or require requesting clinicians to go through additional steps before uploading
pathology reports to the MHR. If all pathology providers were required to upload pathology reports for consenting patients, clinicians could then easily check
whether pathology tests have been recently undertaken by other providers, and if so, access the reports without submitting patients to have additional tests. It is
impractical for clinicians to contact all pathology providers to seek a pathology report if the patient is unsure which provider they used and upload to the MHR
would resolve this.
To better progress and achieve the stated objectives, uploading pathology reports to the MHR for consenting consumers must be mandatory for all pathology providers. It could be tied to Medicare rebates or incentives.
There is significant benefit to the community and clinicians in having important public health tests such as COVID results uploaded to the MHR and immediately
available i.e. not subject to a 7 day delay. Important results such as COVID test results should be displayed or at the very least alerted to on the home report
page rather than hidden in the pathology drop down directory. The seven-day delay rule for other tests could be reviewed.
There remains considerable confusion from the public about how to access their MHR. The AHDA must make it easier for people to access and use the MHR.
Recently, patients contacting a public pathology call centre indicated they have no idea how to access the MHR.
To be able to locate pathology reports in the MHR, it is important to include a search by test name function, not just by date as patients may be unable to recall when tests were conducted.
The future direction of the MHR should be spelt our more clearly. Plans to improve utility for public health measures should be included and progressed as a priority given the current COVID-19 pandemic.

Review of the My Health Records legislation

Please provide your feedback in relation to the specific issues identified in the consultation paper on the operation of the My Health Record system

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The MHR, unlike other systems, permanently deletes records when this option is selected by consumers. This should be changed so that when consumers delete
records they are securely hidden from view but accessible should they be required for legal reasons.
There should be clarity about use of the MHR upon a person's death. The record should be able to be used during autopsy. The MHR should be able to be used
to ascertain consent for organ donation. Autopsy reports and death certificates should be able to be uploaded to the MHR.
Patients may be unaware of consent settings for use of their MHR data for secondary research purposes. This should be more broadly communicated.
It is very difficult for consumers to understand why results may not appear in the MHR and how they should go about seeking resolution to issues which impede
the display of results. Issues may arise because of a lack of concordance with the State Government Hospital identifiers for example.
To troubleshoot issues, it is important that there are all the elements required for a testing system. Providers can’t load dummy patient data and can only test on
the live system currently.

Review of the My Health Records legislation

Please provide any additional feedback for the review of the My Health Record legislation

Please leave your comments below
A review of privacy safeguards should accompany any recommendations from this review.