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NASSCOM-DSCI on National Health Stack: separate regulatory body for health, siloed registries, usage of single ID

In its response to the Niti Aayog's paper on the National Health Stack, industry body NASSCOM and DSCI suggested an independent regulatory body for oversight in the digital healthcare sector, "this is essential to ensure a system of checks and balances" said the two bodies in a joint submission to Niti Aayog. Niti Aayog had released the National Health Stack paper in July 2018 and invited comments on it. The Ministry of Health later formed an inter-ministerial committee headed by former UIDAI chairman and former MeitY secretary J. Satyanarayana to draft an implementation framework for the NHS. The committee released its report the 'National Digital Health Blueprint 2019' in July 2019, and invited comments, and held a public consultation on it. The main points from their submission are: 1. Decentralised governance model, separate regulatory body: The NHS system should allow for multiple operators with the ability to port and access data from each other, instead of restricting to one operator There is no mention of how the geographical architecture of a state level subject will interact with national level system, for example the question of inter-state portability for cashless treatment when a patient might require hospitalisation when out of their home state; this design principle needs consideration in the architecture of NHS 2. Overall centralised structure: The overall architecture of the NHS seems to be a centralised structure, which is not aligning with newer trends towards decentalisation aka blockchain. Restricting system-building approaches to be centralised may not benefit the health…

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