I am delighted to be able to provide feedback on the proposed changes to the PCEHR system. My comments are brief, so I will provide them in dot point format.

Congratulations on making the system opt-out. This is a much better approach.

I fully support the trials, and we would be delighted to take part if that is appropriate.

The new name is more user friendly and catchy.

I am concerned with the decision to make healthcare provider organisations opt-in. I think this creates a sub-system of the original problems with the PCEHR. Opt-in will only work if there are suitable financial incentives for practitioners to take the time and effort to load the information (through the MBS?), or through the Practice Incentive Payment (PIP) system if the Practice Manager is able to do this.

My other concern regarding Opt-in is whether Allied Health and Specialists will receive incentives to upload into the system? If they are ignored, how functional is the system without them? I notice you flag a role for the Primary Health Networks, but they might get as far as assisting Allied Health, but are unlikely to reach Specialists.

Loading health assessments into the PCEHR is probably a good idea, but will this pull Allied Health and Specialists into the system? I am not convinced.

While only an issue for the System Operator, it appears ludicrous for records to be kept for 30 years after you die (or 130 years). Is this really necessary???? The data storage costs will be prohibitive over time?

Penalties for misuse of information. I would hate to see criminal penalties introduced for incidents which are genuine mistakes, however I think incidents that could be considered wilful acts to breach people’s privacy, not limited to, but including, identify theft issues and trolling (deliberate destruction of an individual over the internet) should have criminal remedies apply to them. Trolling is an international activity, so particular thought should be given to chasing people from other jurisdictions that hack personal information.

K Gunn
Balance! Healthcare Pty Ltd
NSW 2128