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Summary: Consultation Paper Published on Healthcare Professionals Registry, Public Comments Invited

Surgical masks spread out

The HPR is set to replace the Doctor’s Registry which raised concerns of digital infrastructural gaps and excluded allied healthcare professionals like lab technicians. 

The National Health Authority under the Ministry of Health and Family Welfare (MoHFW) recently published a consultation paper on the Healthcare Professionals Registry (HPR), one of the core building blocks of NDHM. The idea behind the HPR is to create a recognised registry of healthcare professionals operating within India’s healthcare ecosystem. 

The National Digital Health Mission (NDHM) was introduced as an implementation strategy to digitise existing records of healthcare providers, facilities, and electronic patient records. Certain building blocks have been identified to design and deliver services under the NDHM, with some of them being registries. These core building blocks are:

  • Health ID 
  • Health Facility Registry (HFR)
  • Healthcare Professionals Registry (HPR) 
  • Security Operation Centre (SOC) 
  • Privacy Operation Centre (POC) 
  • Standard API/Master Data 
  • Drug Registry 
  • Health Analytics 
  • Health Data Fiduciary Registry (HDFR)

The NDHM is guided by the principles of the National Digital Health Blueprint (NDHB). In the original NDHB, a ‘Health Workforce Registry’ was proposed to serve as a database for information on doctors, nurses, and paramedical staff. When the NDHM was rolled out in its initial pilot phase in 6 UTs last year, the registries launched were the Health ID, Doctor’s Registry – containing only information on doctors, and the Health Facility Registry (FHR). 

Referring to the limited scope of the Doctor’s Registry, the paper says that “the current registry needs to be expanded to include categories of Healthcare Professionals (HPs) other than doctors.” It is a good time to point out that The National Commission for Allied and Healthcare Professions Act, 2021 recently came into force and seeks to regulate allied healthcare professions such as laboratory technicians, radiographers, etc. This Act defines ‘allied healthcare professionals’ who will be covered under the HPR. 

Also read:  The National Health Stack Is Shaping Up: Doctor Registry In The Works, Test Environments To Go Live On June 30

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Certain issues have emerged post a previously-held consultation with stakeholders that involved doctors, various professional bodies, and registered medical societies with regard to the Doctor’s Registry, such as: 

  • Digital infrastructural gaps, lack of internet connectivity
  • Difficulty in maintaining data for healthcare professionals due to infrastructural deficits and lack of digitised record keeping 
  • A need for grievance redressal mechanisms as Doctors were concerned that legal actions against them may arise due to the technological malfunctioning of such a platform

To address these concerns: legal safeguards, inclusion of allied healthcare professionals, data protection and privacy, referring to and learning from international healthcare models, and designing an app with functionality in mind, is said to have been suggested by stakeholders. 

Here, we will highlight the key issues that were framed in the paper on HPR. You can view the consultation paper here. 

Key information regarding the consultation paper:

  • Written comments on the Consultation Paper are invited from stakeholders by July 13.
  • Comments are to be preferably provided electronically on the NDHM website via form available at https://ndhm.gov.in/publication/consultationpapers.
  • The comments may also be sent to Vikram Pagaria, Joint Director (Coordination), National Health Authority, on the email ID ndhm@nha.gov.in.

The consultation paper comes almost a year after the Indian technology lobby iSPRIT proposed an electronic registry system as a mechanism for “managing master data about different entities in the healthcare ecosystem,” and had propagated open APIs for registries in the National Health Stack (NHS) “for secure authentication and data sharing”. 

Current scenario in India

An observation was made in the paper that there currently exists no nationally recognised, digitally-enabled database on HPs in India. The MoHFW proposes to address this issue through the creation of an HPR. 

In order to lay the framework for analysis of the HPR, three key dimensions have been identified:

  1. the challenges of existing registries and data management of HPs in India 
  2. the current regulatory framework and laws that govern HPs, and
  3. the models adopted by the US, UK, and UAE to manage a register of HPs through digital systems.

Stakeholders

The stakeholders have been broadly categorised into two groups:

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  • Core Registry Participants consisting of stakeholders who will directly benefit from the enrolment of healthcare professionals in the registry 
  • Ecosystem Participants comprising those who will benefit from the creation of other business applications that will leverage the HPR database 

Key stakeholders and a preliminary list of their incentives to be adopted:

  • Healthcare Professionals 
  • Students / Apprentices / Professionals in Training 
  • Patients Healthcare facilities including hospitals, clinics, diagnostic centres, laboratories etc. 
  • Regulatory bodies / Councils Pharmacies/ Pharma Companies 
  • Policy makers/Government Industry Trade Groups / Professional Associations 
  • Insurers 
  • Educational institutions 
  • HealthTech

Different approaches to HPR

The paper implies that if NDHM is adopted nationally, HPR may enable various incentive mechanisms, which can directly enhance the patient experience (e.g., Telemedicine). It examines two potential approaches along with their implications and risks:

  1. Patient-Centric Model The model proposes to include only those HP categories that directly interact with patients to provide health services. While medical doctors would be included, a lab equipment technician would not.
  2. Ecosystem-Centric Model Designed with a view towards creating an integrated digital ecosystem to govern the healthcare workforce. Allows a much broader set of HPs who may operate independently or within healthcare facilities. In addition to the categories outlined in the patient-centric model, health service managers and support staff, life sciences workers and researchers, will also be counted.

The following categories of HPs will be included in the second model

  •       Doctors (Allopathic + AYUSH)
  •       Physiotherapists
  •       Dentists
  •       Dieticians and Nutritionists
  •       Nursing Professionals
  •       Personal Care Workers
  •       Midwifery Professionals (Paramedics Community Health Workers)
  •       Healthcare Facility / Lab Technicians Support Staff (Housekeeping, Security, etc.)
  •       Health Service Managers
  •       Environmental Safety Officers

How will the HPR data be managed?

Mode of Data Entry

For the HPR platform, the Self-Registration mode is proposed. Healthcare professionals will have to enrol themselves in the registry and their authentication is to be done through the NDHM ID service. Post authentication, the HP can provide their data (e.g., educational, registration and employment, etc.) in a ‘Declared’ status on HPR and submit their application.

Data Types

The various types of data on HPs proposed for inclusion in the HPR platform, as well as the concerned authority for verification outlined in the paper, are:

  • Demographic Information (Name, Gender, DOB, Address, etc.) 
  • Language Spoken Educational Information (Course Name, Awarding Institution, etc.) 
  • Registration / Licensing Info (Registration Number, Registering Authority, etc.) 
  • Place of Practice (Affiliated Health Facility, Affiliated Government Health Programme) 
  • Other (Any other entity-specific attributes requested by any external entities and approved by NDHM)

Two verification mechanisms have been suggested in the paper for the verification of self-declared HPR records:

  1. By Verifying Authority / Governing Council: Verification is conducted by any external verifying authority. 
  2. By Health Facility: The healthcare facility assumes responsibility for verifying the credentials of a particular HP.

Notably, the paper calls for enabling an HPR-HFR linkage to allow all records verified in the HPR to be linked with records in the Health Facility Registry. It is pointed out that this linkage is a two-way process – facility managers may declare that a certain HP is affiliated with them, and the declared HP may approve or deny this linkage.

The paper proposes two types of  data governance models:

  1. Decentralised Data Governance Model – Here, responsibility for data quality in HPR lies with the existing government authorities that are legally mandated to regulate various categories of HPs. NDHM’s responsibility is limited to providing an IT platform and integrating various datasets, and building digital verification mechanisms to ensure that these external bodies can view and verify these records.

Features:

  • NDHM / NHA will not be accountable for the veracity of HP data. NDHM will only assume the responsibility of collaborating with external entities to build tailored verification mechanisms, and indicating whether a particular data point is ‘Declared’ or ‘Verified’.
  • Wherever regulatory authorities have digital databases exist, HPR will only maintain a slave database that will be kept synchronized with the master database.
  • Data ownership will rest with the registrant who has declared their details during enrolment. However, the liability for data veracity will rest with the external regulatory body. 

     2. Centralised Data Governance Model

NDHM will liaise with the concerned governing councils to maintain the HPR dataset. NDHM will be responsible for maintaining the Master Database of information on HPs, where any changes are initiated. However, it is pointed out that NDHM will not assume legal responsibility or infringe upon the jurisdiction of existing government authorities that are responsible for regulation of any category of healthcare professional.

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Features:

  • Where available, NDHM will adopt the verification processes of governing councils or other external entities, and will digitally enable these verification mechanisms and implement them.
  • NDHM will maintain the master database, with the governing councils or external entities maintaining replica databases.
  • Data ownership will rest with the registrant who has provided their details during enrolment. If grievances are raised regarding the veracity of HP data, NDHM will liaise with concerned governing councils to take action.

While the Decentralised Model may not be ideal in as much as it leads to exclusion of many allied healthcare professionals, there are major concerns of data breach and excessive control of the NDHM over our health data in the Centralised Model. These concerns get more pronounced by certain facts such as ambiguity around the entities involved in developing the tech to see through NDHM, and the fact that India still does not have adequate data protection laws or appropriate authority to regulate this space. In this scenario, putting out such sensitive data over a platform seems rushed at the very least. 

iSPRIT’s Role In Developing the HealthStack

With regards to ambiguity around those involved in developing the Health Stack, iSPRIT’s role still remains largely unexplained. While the tech lobby group has claimed that it is only building the public infrastructure for digital health in India, Medianama has previously pointed out certain indications that it has a significant part to play in the NDHM’s roadmap and rollout. 

A webinar organised by iSPRIT last year on Personal Health Records (PHR) and Doctor’s Registry, the design principles envisaged by iSPRIT find a place in the consultation paper as well. For instance, designing interoperable registries for sharing data across platforms through open APIs is similar to what iSPRIT has suggested. Specifically, in terms of the Doctor’s Registry, the design principles of iSPRIT that have been directly adopted for the HPR mechanism are : 

  • a self-maintainable’ registry where doctors enrol themselves and update their own data
  • The data should be digitally signed by a relevant attester such as a State Medical Council, so that it can independently be verified by anybody
  • The registry must be convenient to use so that doctors have an incentive to keep it up to date. Eg. doctors can use their registry profile to electronically sign prescriptions, insurance claims, etc., or doctors can use their registry profile to streamline and digitize the process of renewing their medical licenses (Even the instance used to explain this incentive by iSPRIT finds a mention in the consultation paper)

Of course, the MoHFW has gone to great lengths to dissociate itself from any kind of preferential treatment towards iSPRIT or any particular industrial lobby, such as the detailed statement it sent in response to an article that questioned the involvement of iSPRIT in the NDHM rollout process.

MediaNama looks forward to your comments on this consultation paper. 

Also read:

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