“We strongly recommend that the government should not dictate and control the business models of the EUAs (End User Applications). It should be based on a free-market model, where-in every EUA should have the freedom to decide its own business model, as per business viability,” Healthcare application Practo told the National Health Authority in its comments on the proposed Unified Health Interface (UHI).
The UHI, which would form the second last layer of the government’s multi-layered National Digital Health Mission (NDHM), defines how third-party End User Applications (EUAs) like that of Practo and hospitals would interact with the NDHM. To provide the integration, UHI proposes to charge them some fees as well as set ground rules for how they could conduct their businesses while on the platform.
On September 2, the NHA made public the submissions by various health service providers and digital health stakeholders on the proposed UHI and other components of the National Digital Health Mission. This included comments by Practo, one of the most prominent health applications in the country. In its submission, Practo raises concerns about potential digital health monopolies, reduction in quality of patient care, and more which are significant given its stake in the healthtech sector with a claim to have over 17 crore customers.
Practo’s submissions to the National Health Authority
1. On the Open Network Approach
The NHA proposed that an Open Network Protocol could be used for dispensing digital health services that are based on shared technical standards which will allow healthcare service providers as well as patients to use one platform.
What Practo says: Could enable monopolies
The UHI would lead to monopolies and oligopolies along with the commoditisation of healthcare as an End User Application–with experience in healthcare or not–will be able to participate in the NDHM, it said. This it said was because companies with maximum customer reach would have an undue advantage to become the largest app. In time, this would also dissuade small innovators and investors from venturing into the sector.
Practo suggested that the NHA conduct extensive industry consultations around policies related to the UHI, noting that it could transform the Indian health ecosystem.
2. On listing all registered Health Professionals
The NHA has laid down that all End User Applications, like Practo, who would participate in the NDHM would have to list all the doctors who have enrolled themselves into the HPR so a patient could discover and consult with them.
What Practo says: affects patient experience
According to Practo, this would affect the patient experience. The End User Applications lists doctors based on their experience, knowledgeability, etc. These, in turn, impact parameters like user affinity, users previous interactions, recent Health Service Provider’s performance, etc. and help an End user application distinguish itself from others.
Thus it said that after the introduction of UHI (in its present format) the End User Applications would not be able to curate doctor networks based on quality parameters that its users expect and should get.
Practo suggested that End User Applications be given the freedom to list doctors based on expertise, quality, experience etc
3. On Pricing
The NHA proposed a three-part pricing mechanism for services on UHI: Health Service Provider (HSP) price for service + UHI Gateway charges (if any) + End-User Application (EUA) service charges. It also said that in the long run, it could consider charging HSPs or EUAs for access to the UHI.
What Practo says: restricts business model
The suggested pricing model Practo says would impact business models as well as the innovation undertaken by EUAs. It further elaborated saying that, unlike commodity transactions, Healthcare innovations have been circling around models of subscriptions.
The proposed pricing mechanism would hurt the EUA by restricting them to an OTA based business model and it would also limit them by making them mere channels for a patient to find a doctor with no innovative pricing offerings.
An OTA based model involves a charge for the facility of discovering a service provider.
Practo suggested that the End User Applications be given the freedom to choose their own business models.
Comments and consultations so far
At an Open House held for consultation on three NDHM components- UHI, Health Professionals’ and Facilities’ registry- last week, the NHA revealed that it had received 329 comments so far.
Out of this:
- 48% were on the Health Professional’s Registry
- 33.4% were on the UHI
- 18.5% were on the Health Facilites’ 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, it also noted that this marked the fourth stage of its consultative process on different parts of the NDHM. Previously it had conducted consultations on the
- NDHM draft implementation strategy,
- NDHM blueprint,
- NDHM data policy,
- Sandbox framework guidelines, and others.
- Open House on National Digital Health Mission: Stakeholders want no liability for data, fair discovery, and more.
- Why did RS Sharma bring up UPI and Account Aggregators in an event on digital health?
- Unified Health Interface: IT For Change warns against oligopolies, raises privacy concerns