The Indian Medical Association (IMA) has raised concern over national digital health blueprint document published by the government of India recently, which comprises an ambitious plan to bring a digital ecosystem of digital health network under national digital health mission.
IMA stated that National Digital Health Mission, stemming from the National Health Policy of 2017, is purported to digitise the entire healthcare eco-system in India.
“India still lacks adequate healthcare infrastructure and manpower. There is no standardisation of many streams of treatment adopted in our country. The government is adopting strategies to allow untrained and partially trained individuals to practice medicine to address the manpower shortage,” stated Dr Rajan Sharma, national president, IMA.
Primary care, strengthening of public health infrastructure and human resources as well as addressing the social determinants of health is our priority, added IMA.
Dr RV Asokan, secretary general, IMA adds, “Funding for such an ambitious plan is not appropriately described. Any diversion of funds from NHM will further jeopardise the public funded health care, especially primary care. Hence there is a definite possibility of the plan to become a non-starter if the investment in health care is not significantly increased. Out of pocket expenditure in health care will increase further in such a situation.”
“Primary care has lost focus and the proclaimed Wellness centres are yet to make an impact. There is skewed distribution of medical training infrastructure,” stated IMA.
Sharma added, “Data protection is another area of grave concern. Apart from the issue of privacy, management of analytical data by the agency is poorly defined in the document. The management of analytical data will be governed by data protection laws which is practically nonexistent at present.”
“Before addressing that issue, it is prudent to understand whether the Union Government is vested with the requisite legislative powers to formulate a pan-India policy to establish the mechanism outlined by the NDHM. Assuming that the Union government is competent to bring forth the NDHM Policy into force, it appears to face hurdles in its implementation. The practice prevalent in the healthcare community vis a vis the confidentiality of a patient’s medical records is entrenched in the fundamental principle of doctor-patient confidentiality relationship. This principle finds legislative backing in the Indian Medical Council (Etiquette and Ethics) Regulations 2002,” said Dr Asokan.
He added, “Privacy is of utmost concern. Privacy protection laws in India are weak and practically nonexistent. Privacy is being ensured through consent manager in NDHB. The consent in digital platform in a country where literacy is low is cause of concern. The consent mechanism described in the document is inadequate to address the concern.”
IMA is of opinion that the NDHM policy does not satisfy the rigours of protecting the fundamental right to privacy under Article 21 of the Constitution of India. It is also our considered opinion that the policy strikes a discordant note with the existing rules and regulations pertaining to medical practice in India.
IMA added that NDHM leverages well defined consent management framework. There are several consent models used by HIEs and the consent management framework should be flexible to adopt varying needs of the citizens.
The implementation of National EHR is a complex task and it requires serious well thought out planning backed with strong global healthcare informatics expertise and a badly designed national electronic health record (EHR) system will not only be a pain for clinicians for but also could endanger patients as we have seen in other countries where the cost of redesign is significant, added IMA.
Unique identification of persons, facilities, diseases and devices is a key requirement as well as a challenge in the National Digital Health Ecosystem (NDHE).
There should be appropriate regulations to define how the data and health information will be shared, between whom and to what extent, stated the IMA.
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