“[The] last point in the eligibility criteria stating ‘Any private or autonomous body involved in granting empanelment or certifications to health facilities’ should be omitted. Involving private bodies will dilute the entire verification process,” the National Accreditation Board for Hospital and Healthcare Providers told the National Health Authority (NHA) in its comments on the proposed Health Facility Registry (HFR).
The Health Facility Registry, a part of the government’s multi-layered National Digital Health Mission (NDHM), would be a database of all health facilities – labs, hospitals, clinics, etc – in the country after verification by health facility verifiers.
On September 2, the NHA made public the submissions by various health service providers and digital health stakeholders on the proposed HFR and other components of the NDHM. This included comments by NABH, an accreditation and empanelment body for hospitals and healthcare providers under multiple government health schemes. The NABH, in its submission, raised important points on how health facilities should be included in the HFR, including verification processes, eligibility, and more.
What the NABH said about HFR
On integration of other databases with HFR
NHA: The health authority invited suggestions on how should a Health Facility Registry organisation/programme be able to interact with the HFR. HFR Organisation/ Programme Entities are entities engaged in activities like granting licenses and certification to health facilities, implementing the government health and insurance programmes and schemes, empanelling hospitals as insurance companies, etc.
- NABH along with other constituent boards of the Quality Council of India (QCI) should be considered for the role of a Health Facility Organisation. QCI is a government body which ensures the adoption of certain quality standards across various bodies and sectors like healthcare.
- Its own database of 12,000 healthcare facilities be integrated with the HFR.
On criteria for selecting Health Facility Registry organisations
NHA: Suggestions were invited on the proposed criteria and scope of function of an HFR Organisation/Programme.
NABH suggested that private organisations should not be allowed to become HFRO’s as it would dilute the verification process. It suggested that organisations with ‘repute’ should be given the responsibility instead.
On terminology for ‘Health Facility Verifier’
NHA: Suggestions were invited on the terminology, nomenclature of the term ‘Health Facility Verifier’ (HFV). According to the NHA, ‘Health Facility Verifier’ refers to an independent, third-party legal entity enrolled in NDHM that is responsible for the verification of data in the HFR.
NABH suggested that the term be changed to ‘Health Facility Verifying Organisation’, as the current term gives the idea that the Health Facility Verifier is a single person.
On criteria for Health Facility Verifier selection
NHA: Suggestions were invited on the two proposed methods to select a health facility verifier. The two methods were either a Standing Committee or the National Health Authority itself would oversee the shortlisting, verification, and training of the potential verifiers.
- The first method to selecting a Health Facility Verifier be taken, involving a standing committee.
- The NABH and ‘sister boards’ be selected as Health Facility Verifiers.
On data fields for registration of health facilities
NHA: Comments were invited on the thoroughness of data fields listed by the HFR consultation paper for registering health facilities along with suggestions for what more could be added.
NABH suggested that accreditation bodies listed by health facilities should have International Society for Quality in Health Care (ISQua) accreditation for their organisation, and not just for their standards. ISQua is a not-for-profit entity that provides accreditation to healthcare organisations worldwide, based on its standards.
Comments and consultations so far
At an Open House held for consultation on three NDHM components – Unified Health Interface, Healthcare Professionals Registry, and Health Facility Registry- on September 6, the NHA revealed that it had received 329 comments so far.
Out of this:
- 48% were on the Healthcare Professionals Registry
- 33.4% were on the Unified Health Interface
- 18.5% were on the Health Facility Registry
Further by area of concern
- 23.4% were on implementation – as in how the concepts would be implemented across the country, in areas where other infrastrucure is weak.
- 25.3% were on policy – such as data sharing mechanisms, data regulations, etc.
- 51.1% were on product – such as the design principles as well as technological aspects of the building blocks
During the Open House, the NHA also noted that this marked the fourth stage of its consultative process on different parts of the NDHM. Previously it had conducted consultations on:
- NDHM draft implementation strategy,
- NDHM blueprint,
- NDHM data policy,
- Sandbox framework guidelines, and others.
Also Read (feedbacks submitted by other stakeholders):
- NDHM Consultation: What Did FICCI, IAMAI, NASSCOM, And CII Say About The Unified Health Interface?
- NDHM Consultation: Practo says UHI could enable healthcare monopolies
- Amazon Internet Services Calls For Greater Private Sector Involvement In Proposed NDHM
- IT For Change Warns That Proposed Interface Under NDHM Might Establish Oligopoly In Digital Health
- Open House on National Digital Health Mission: Stakeholders want no liability for data, fair discovery, and more.
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