Advisory AS18/11: Implementing systems that can provide clinical information into the My Health Record system

Advisory details

Purpose

To describe the minimum requirements for health service organisation compliance with Actions 1.17 and 1.18 working towards implementing the My Health Record system.

Issue

Actions 1.17 and 1.18 are requirements in the National Safety and Quality Health Service (NSQHS) Standards. These actions relate to health service organisations using My Health Record system. 

The subjects of this Advisory are Action 1.17 and Action 1.18.

Action 1.17 states:

The health service organisation works towards implementing systems that can provide clinical information into the My Health Record system that:

1. Are designed to optimise the safety and quality of health care for patients
2. Use national patient and provider identifiers
3. Use standard national terminologies

Action 1.18 states:

The health service organisation providing clinical information into the My Health Record system has processes that:

1. Describe access to the system by the workforce, to comply with legislative requirements
2. Maintain the accuracy and completeness of the clinical information the organisation uploads into the system

This advisory describes the minimum actions a health service organisation must demonstrate to be compliant with the requirements of Action 1.17 and the processes for Action 1.18.

The NSQHS Standards complement the requirements set out in Part 5 of the My Health Records Rule 2016 (the Rule). The Rule outlines the requirements for providers contributing to the My Health Record system, to ensure the safety and quality of health care provided to patients. These requirements should be described in organisational policies and procedures. 

In relation to the use of national patient and provider identifiers, health service organisations are expected to have identity management systems that align with the national Healthcare Identifiers (HI) service. This includes collecting patient demographics to obtain or revalidate a patient’s Individual Healthcare Identifier (IHI). In addition, health service organisations have systems to maintain and monitor the use of Healthcare Provider Identifiers for organisations (HPI-Os) and individual providers (HPI-Is). 

Health service organisations that provide (or are working towards providing) clinical information into the My Health Record system using standard national terminologies should consider supporting material from the National Clinical Terminology Service (NCTS). Health service organisations are expected to integrate standard national terminologies (for example, SNOMED CT-AU and Australian Medicines Terminology) into their clinical information systems. 

Previous Advisories have required health service organisations to:

• Complete a gap analysis
• Have developed a detailed plan.

Requirements

To comply with Actions 1.17 and 1.18, health service organisations must:

• By June 2024, have developed a detailed plan that complies with:
  • all requirements of Part 5 of the Rule; 
  • use of national patient and provider identifiers (IHIs, HPI-Os, HPI-Is^[*]); and,
  • use of standard national terminologies.
• By December 2024, have ongoing monitoring and evaluation of compliance with the requirements of Action 1.17 and 1.18.

Accrediting agencies are required to:

• Review evidence that:
  • From July 2024, the organisation has completed a gap analysis, has a detailed plan and the plan is being implemented
  • From January 2025, the organisation has as system to monitor and evaluate compliance with Action 1.17 and 1.18.
• Rate Action 1.17 as met, only if the organisation demonstrates achievement of the specific requirements of the Action in the relevant year.
• Rate Action 1.18 as met only if the organisation demonstrates embedded processes in accordance with the specific requirements of the Action in the relevant year. 
• Rate Actions 1.17 and 1.18 as met with recommendations if there is evidence of a gap analysis and finalised plan endorsed by executive and the plan is being implemented and monitored (NB. where these requirements are met, these actions may be rated ’met with recommendation’ for no more than one accreditation cycle).

Resources are available from the Australian Digital Health Agency’s website and My Health Record website, which provide further information on the My Health Record system.

In July 2023, the Australian Digital Health Agency (the Agency) published Australia’s first national plan to deliver a connected healthcare system; the Connecting Australian Healthcare – National Healthcare Interoperability Plan 2023-2028. An action under Priority 1 – Identity, is to review and adopt national healthcare identifiers and promote healthcare organisations’ implementation of HPI-Is. HPI-Is are used as part of My Health Record and Electronic Prescribing conformance. 

The Agency has provided HPI-I exemptions to healthcare organisations due to their varying levels of HPI-I readiness. In June 2023, the Agency advised health service organisations that HPI-I exemptions would expire after 30 June 2024.

Australian Digital Health Agency resources

• National Digital Health Strategy 2023–2027
• National Healthcare Interoperability Plan 2023–2028
• The Digital Health Blueprint and Action Plan 2023–2033
• Understanding national identifiers
• Introduction to clinical terminology
• My Health Record stakeholder materials (for healthcare professionals)
• Roles and responsibilities – when registering to use My Health Record system
• Webinars for healthcare providers
• Sample digital health policies (downloadable templates)
• Data quality checklist of ‘active’ patients
• Software simulations
• National Clinical Terminology Service
• Security and Access policy template

• ^[*] Healthcare Provider Identifier – Individual (HPI-I)