Review of the My Health Records legislation

WA Primary Health Alliance (WAPHA) oversees the strategic commissioning functions of the Perth North, Perth South and Country WA Primary Health Networks (PHNs). As the operator of WA’s three PHNs – part of the Australian Government national PHN program – we plan, guide and direct investment towards important primary healthcare services. We shape, strengthen and sustain a health system that works for people. Our state-wide structure and strong partnerships give us an opportunity to shape a health system fit for the future.

Since the launch of My Health Record, WAPHA has been actively engaged in promoting the use of My Health Record amongst consumers and health professionals across WA. We have engaged with 100% of general practices and pharmacies to ensure awareness of My Health Record and to offer training. In recent months, WAPHA has worked to support the use of My Health Record for Goals of Patient Care documents and Advance Care Planning. In WA, we are seeing increasing levels of engagement with My Health Record across the health system. Key milestones this year in WA have included:
• BreastScreen WA became the first breast screening service in Australia to connect to the My Health Record system, allowing women to see their mammogram results as soon as their test is assessed.
• South Metropolitan Health Service and WA Country Health Service commenced the upload of Goals of Patient Care (GoPC) clinical documents to My Health Record.
• As part of the COVID-19 response, all public pathology laboratories in Western Australia were connected to the My Health Record system, providing secure and convenient access to COVID-19 screening for patients and clinicians.

WAPHA recognises the important role that My Health Record can play in improving health outcomes, delivering more coordinated care, and creating a more efficient, integrated health system. Thank you for the opportunity to provide feedback as part of this consultation.

1. Is MHR providing important practical healthcare benefits to consumers and providers? Could more be done to improve the benefits that are provided? Could more be done to generate better public understanding of the healthcare benefits of MHR?

There is still limited understanding regarding the benefits of My Health Record and how it can be used. Figures relating to the use of My Health Record by Providers show that in WA there has been a significant increase in utilisation over the past year, from around 80,000 in August 2019 to around 167,000 in August 2020. We have also seen increasing interest and utilisation of My Health Record by hospitals and state services.

However, there is insufficient data available to understand utilisation of My Health Record by consumers and anecdotal evidence from our work promoting My Health Record suggest that consumer utilisation is limited. In addition, it can also be challenging for consumers to navigate and engage with My Health Record when not all health care providers are using it.

WAPHA recommends that further work could be undertaken to promote and encourage the use of My Health Record by consumers. Best practice examples could be used to promote the value proposition for both consumers and health professionals. In addition, case studies could be used to demonstrate how My Health Record benefits consumers, particularly around access to immunisation records, the ability to store Advance Health Directives and how consumers can be empowered to add their own health information/records to their My Health Record.

2. Are there any particular features of MHR that make healthcare recipients or providers reluctant or disinclined to use it? Is there unnecessary complexity in MHR legislation?
WAPHA has received the following feedback from stakeholders regarding potential barriers to utilisation of My Health Record:
• The lack of consistency of information has been flagged as an issue by Providers. Achieving universal coverage (or as close to it as possible), as in all pathology results or all specialist letters are uploaded to My Health Record, will be an important step in building trust in the system and will encourage Providers will be to use it as a primary resource.
• The Provider portal for services that are not using conformant software is essentially unfit for purpose. It is time consuming for Providers to log in and then it automatically logs them out after 15 minutes, meaning that the provider then has to log in again towards the end of the consultation. This is time consuming and a key barrier to utilisation.
• For some Providers, particularly specialists, the inability for non-clinicians to access the record is a barrier, as non-clinicians are often the staff responsible for gathering and preparing information prior to the consultation.
• From a consumer perspective, access to My Health Record via MyGov is a barrier, particularly when trying to access information via a smartphone, which is often the case when the individual is at their appointment or seeing a health professional.
• As noted at Question 1, there is still a low level of consumer knowledge around what benefits a My Health Record can provide and what it could or should contain. Anecdotally, consumers see My Health Record as a tool for health professionals, not for themselves personally.

It may be appropriate to consider a consumer survey, potentially targeted through relevant health consumer organisations, to further understand barriers to utilisation.

3. Is the scope and purpose of MHR clear? Is there a need to define or explain MHR more clearly, and how it relates to other health information systems and practices?

There continues to be misunderstandings among some consumers, health care professionals and health services regarding the scope and purpose of My Health Record. It may be helpful to:
• More clearly define the purpose of My Health Record, and the value proposition for consumers and health professionals.
• Explain where My Health Record ‘fits’ within other health information systems. For example, explaining to consumers that their GP, specialist, local physiotherapist and hospital each have medical records that are separate and cannot always be linked. For services, it may be helpful to provide examples of how My Health Record can be integrated into the service workflow. For example, WAPHA has made a My Health Record Urgent Care Workflow and a My Health Record General Practice Workflow available to practices.
• Prioritise information/records that should be in My Health Record, so that consumers and health professionals can focus on ensuring that information is uploaded. This could then build and change over time, to work towards a more complete record. It would also help to build confidence among health professionals about what they can expect to see in a patient’s My Health Record.

4. Should the future direction of MHR be spelt out more than at present? What issues should be covered in a futures roadmap or strategic plan?
The future direction of My Health Record should, to the extent possible, be clearly communicated to stakeholders. At present there can be challenges from a PHN perspective in terms of planning and preparing for improvements and changes to My Health Record because is often at short notice. Generally, we have found that successful implementation of any policy or programs change (big or small) is dependent on:
• Establishing effective, collaborative relationships with providers, peak bodies and other key stakeholders.
• Having time to prepare Providers and consumers for change.
• Communicating key messages to highlight what the change is, how it will impact the Provider and/or consumer, and what the benefits are.
• Communicating the change in the context of the broader health policy environment, such as linking to concepts such as team-based care and the Quadruple Aim.

In future, WAPHA would like to see the potential for coded data explored further. Due to the nature of the record currently, it is very much view only and can be time-consuming to search through the record for pertinent information. Having a coded database would benefit in multiple ways, including:
• Being able to search for keywords/diagnosis/test results which would reduce the need to manually look through each record.
• Potentially allow for the two-way transfer of information. For example, to pull specific information from My Health Record into the correct locations in a locally held record.
• Potentially allow for key information, such as allergies, safety alerts to be flagged in the local clinical system.

WAPHA would welcome opportunities in the future to provide feedback on My Health Record and opportunities to improve this important initiative. In addition, some stakeholders have expressed the sentiment that My Health Record feels like it is ‘top down’ and Providers would welcome more opportunities to influence future plans.