The PIP QI program went live on 1 August 2019.
The AGPA and a group of concerned Doctors reviewed the data collection arrangements for the program and determined that there were significant privacy issues for patient and Practice information.
The Department of Health has now released a new set of guidelines which addresses many of the issues raised by the AGPA.
A win for common sense.
To receive payments under the program General Practices must provide data on 10 key indicators.
As it stands the program requires that Practices provide the data to their PHN. The PHNs have outsourced the data collection, and while the information may be de-identified it is not clear when it is de-identified or how much data is being extracted from Practice management systems. The risks of a breach of patient privacy appear to be significant.
A group of concerned GPs and the AGPA prepared a paper that was provided to the Department of Health 31 July 2019 (here) and there was a subsequent round-table meeting of DoH, PIP Advisory Group and AGPA on 2 August 2019.
Following that meeting the AGPA has reviewed that original statement and have taken advice from health experts within the sector including:
- the Medical Software Industry Association,
- organisations which have a proven track record in medical data storage,
- large corporate General Practice groups
and discussed these issues with a range of other concerned General Practitioners including our members.
The AGPA stands by the key points of that statement which in fact were vindicated as legitimate and on-going issues during and after the “round table”.
The intention of the AGPA is to assist a smooth rollout of the QI-PIP program and to ensure that the data collection and storage systems that are in place are of an appropriate standard to protect our colleagues, our patients and the sector to enable good QI initiatives using data whilst ensuring the confidentiality of patient information and commercially sensitive Practice data.
The Alliance recommends the following principles be adopted and incorporated into the QI-PIP program:
- A privacy impact assessment should be undertaken.
- A data governance framework must be established prior to the release of any aggregate data sets to third parties, as has been established with the My Health Record.
- Further consideration be given to avoiding the inherent risk of data collection by 31 PHNs in favour of a single, trusted, national data repository. AGPA is of the view that the Australian Institute of Health and Welfare (as a trusted and respected organisation) has the capability to be that repository, potentially through its integrated “Health care quality and performance” arm.
- Patients should be provided with transparent advice regarding the data collection process and their ability to opt out.
- All patient data be sufficiently de-identified at transmission from the Practice to ensure there is minimal risk of re-identification.
- A single national sign-up contract for General Practice uploads to this data repository.
- The only data elements uploaded to the national repository are the 10 agreed QI PIP requirements represented as ratios rather than atomic data. The QI PIP Eligible Data Set should consist only of 10 ratios, each of which reports the proportion of the Practice’s patients who meet the criterion in each of the 10 measures.
- Individual practice and Doctors’ personal and demographic data must be de-identified and MBS data must be excluded from the collection.
- Practices must be provided with competitively neutral choices regarding the upload tools available including the option for direct upload from native clinical software.
- Data should be made available to PHNs and other interested parties via a secondary use framework.
- Commerciallsation of the uploaded QI PIP data sets must be prohibited under law.
A rationale and some links are here.
The DoH has since issued an updated fact sheet which addresses many of these concerns. The AGPA notes that it still relies on an inefficient process of data collection by 31 PHNs around Australia instead of a a single national data collection and storage program.