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Here’s what the NHA has proposed for building a ‘Unified Health Interface’ in India

Summary of latest consultation paper by National Health Authority (NHA) on creation of an ‘interoperable’ healthcare system, modelled on UPI

Outlining key components of a proposed Unified Health Interface (UHI) system, ways to improve access to healthcare service providers, methods to tackle fake reviews and to prevent monopolies on a digitised health platform are some of the major questions raised in National Health Authority’s (NHA) consultation paper on ‘Operationalising Unified Health Interface (UHI) in India’.

Released on December 15, the paper outlines a framework that enables interoperability in health services and is envisioned as a foundational layer of the Ayushman Bharat Digital Mission (ABDM). As stated in the paper, the document proposes different operational elements of UHI for consultation and “provide adequate context for the citizens and concerned stakeholders to weigh in with their comments”. The public can submit responses through a form until Friday, January 13, 2023.

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What is “interoperability in healthcare”?

A. Ayushman Bharat Digital Mission (ABDM)

The consultation paper notes that the ABDM was launched in 2017 with an objective to “create a national digital health ecosystem that supports universal health coverage in an efficient, accessible, inclusive, affordable, timely and safe manner” in sync with the National Health Policy. ABDM aims to achieve this by prescribing common health data standards, developing core modules such as health facility registry, healthcare professionals’ registry, which form the base of interoperability. The emphasis is on interaction of various digital health systems and “seamless sharing of data across healthcare providers”.

With a focus on UHI and its various operational elements in an evolving ABDM architecture space, the consultation paper stresses on the need to have clear guidelines in place for “fair, efficient and transparent” operations of these digital building blocks.

B. Unpacking Unified Health Interface (UHI)

  • Limitations in the current system: The paper notes that the current digital health ecosystem is highly fragmented, restricting people from access to their preferred choices of healthcare providers or services due to siloed infrastructure. An example can be of limitations that hinder the optimal matching between doctors and patients.
  • UHI network: To fix these limitations, the paper states that UHI will work as an open and interoperable network for End User Applications (EUAs) and Health Service Provider Applications (HSPAs) enabling a different health services such as the following, but not limited to:
  1. Booking physical appointments at hospitals / clinics
  2. Booking Tele-consultations
  3. Discovering availability of critical care beds
  4. Discovery of lab and diagnostic services
  5. Booking of home visits for lab sample collections
  6. Booking an ambulance

    Image source: NHA Consultation Paper on UHI

Citing the case of Unified Payment Interface (UPI) in India, which enables users to choose any apps such as BHIM, Paytm or PhonePe, the paper notes that UHI-enabled applications can allow patients to discover, book, conduct and pay for services offered by “a variety of participating providers from any application of their choice”.

C. Entities of any service transaction in UHI, as stated in NHA’s paper:

  1. User is any patient seeking digital health services through UHI.
  2. End user application (EUA) is any application chosen by the user to access health services. EUAs can be of diverse forms like mobile apps, interactive voice response systems (IVRS), virtual assistants in English and local languages, etc.
  3. Health Service Providers (HSPs) are individual doctors, hospitals, labs, companies that aggregate health services, etc. They provide digital health services using Health Service Provider Applications (HSPA) that uses UHI protocol.
  4. Health Service Provider Application (HSPA) is any provider-facing application allowing health service providers to respond to EUA requests and fulfil digital health services. HSPAs can be standalone providers or aggregators of services/businesses. Through an HSPA, a health professional can manage their services, calendars and payments.
  5. UHI gateway routes the initial service/provider discovery requests and responses involved in UHI transactions between HSPAs and EUAs.

Further, the consultation paper provides a schematic illustration of a patient’s and doctor’s experience on the UHI.

What are the elements in operationalising UHI?

A. Search and Discovery

The NHA lays out a step-by-step plan on how the UHI’s search and response network will enable HSPAs to provide and end users to avail health services. As stated in the paper:

  1. A user searches for a service on an EUA – the search can be in the form of the service, provider, symptom, facility or speciality.
  2. The EUA then routes the search discovery request to the Gateway, which in-turn broadcasts this request to all registered HSPAs to whom this discovery request is relevant.
  3. HSPAs can view the incoming request and decide if they want to respond or not. If an HSPA decides to respond to this request, it can do so by providing the details of their service, price they expect for the service, how they accept payments, etc.
  4. The gateway forwards these results with the end user application, which in turn presents all the choices to the user.
  5. The HSPAs will be able to choose what services they want to provide, and which cities they want to service in. The UHI gateway will respect the preferences of the HSPAs and route the searches to only the relevant HSPAs.
  6. To enable this level of classification, the UHI Sandbox will be designed such that an HSPA can certify themselves for each health service separately and add it to their list of services offered on UHI.
  7. This ‘intelligent routing’ by the UHI gateway will help optimise the search process and maximise overall efficiency.

Some of the examples of service delivery include— discover a doctor for teleconsultation, discover availability of your doctor, discover an ambulance, discover the closest lab and more.

In order to prevent preferential treatment in the search and delivery process, the paper states that the UHI network policy has guidelines in place that NPs have to follow. The guidelines aim to focus on accuracy and transparency of information provided by all UHI entities and on keeping a check on market competition and other discriminatory practices which ultimately affect the end user.

These are the questions for consultation:

  • What are the issues (if any) with the search & discovery process?
  • What more can be done to make the process of search and discovery fair for EUAs and HSPAs?
  • What are some of the ways to level the playing field between start-ups and established network participants to prevent monopolies in the sector?

B. Service Booking

Once a user receives the search results of the service they wish to avail, they can proceed to select and confirm the booking of HSP of their choice. Next, according to the paper, “The EUA, in communication with the HSPA, fetches the details of the chosen service including the available dates & timings for the service, price of the service, offers & discounts (if any), terms and conditions, rescheduling & cancellation policies, etc.” If the terms are suitable to the user, they can confirm the booking and move to pay.

Upon confirmation, “the transacting EUA and HSPA enter into a transaction level contract which lays down terms pertaining to the rights and obligations of both Network Participants”. The UHI policy requires HSPAs to have clear and transparent policies on refund in the event of cancellations, rescheduling and no-show, which will be displayed prominently on the EUA for the user information.

These are the questions for consultation:

  • What are the disclosures, in addition to service charge and cancellation & reschedule policy, that should be made to the user at the time of service booking?

C. Service Fulfilment

The consultation paper states the following points on delivering services to the users across parameters such as time, price and others:

  1. To fulfil a teleconsultation between a patient side and provider side application, UHI offers WebRTC as a video solution and leverages its message API to establish a video connection between EUA and HSPA. While this is available on the UHI sandbox, platforms are not mandated to use this solution for service fulfilment.
  2. In case there is any rescheduling, cancellation or no-show, the refund to the user should be processed as per the terms and conditions of the booking. Any breach of these terms can be grounds for raising a grievance through the Issue and Grievance Redressal Mechanism of UHI.
  3. Upon the completion of the service, the HSPA must report completion of service fulfilment and this would be confirmed by the EUA. The EUA and the HSPA will also be required to send service fulfilment metrics at regular intervals, as decided by NHA.

These are the questions for consultation:

  • In what other ways can UHI ensure interoperability in video calling between the patient side and provider side applications?

D. Payment and Settlement

The paper notes that, while the payment will happen through existing payment systems and will take place outside the network, “the terms of settlement, settlement advice and the proof of payment will be transmitted using the underlying protocol to cultivate trust in the UHI Network”. The NHA has proposed two payment and settlement flows:

a. One where the transaction starts through EUA via Reconciliation Service Provider (RSP) to the HSPA.

b. Here, the HSPA is the collector who will facilitate the process through a payment link to the user.

According to the paper, in both the cases, the collector will be the one settling it as well. Further, for in-person transactions, the HSPA is often the collector of the amount since they are the provider of the service and will settle the amount with the EUA in the same manner as described above.

Further, to ensure that the payment is not used for other expenses in the process, the paper says that the amount will be held in a nodal-link amount until the settlement advice is prepared and shared.

These are the questions for consultation:

  • Who should perform the collection and settlement process for the time being – EUAs or HSPAs? What are the pros and cons associated with each?
  • What are the issues in the system proposed by UHI for payments and settlements?
  • How can the payments & settlement system be made more robust?

E. Reschedule and Cancellation

According to the paper, the HSPAs have to provide clear and comprehensive rescheduling and cancellation policies to the users at the time of service booking confirmation. The UHI does not prescribe a set template for refunds, rescheduling and cancellations, but requires the participating HSPAs to have policies in place that will govern these aspects in a transparent manner, the paper notes.

These are the questions for consultations:

  • What, if any, are the issues in the proposed approach to rescheduling and cancellations?
  • What other mechanisms can be put in place to avoid issues related to rescheduling and cancellations from escalating into grievances?

F. Grievance Redressal

The user or the HSP can raise their grievance in four levels. The paper states the following:

  1. Internal Grievance Redressal Mechanism: Here the NPs will be required “to have internal mechanisms such as an FAQ page, automated chat bot, online customer care portal, customer care number, etc. in place to resolve minor grievances at the app level.”
  2. Resolution through Grievance Redressal Officers (GRO): “If users are not satified, they can escalate the grievance to the GRO of the interfacing application.” All participating NPs will have a Grievance Redressal Officer who will be the primary point of contact in this system.
  3. Resolution through ODR Service Providers: “If neither of the applications claim responsibility for the resolution of the grievance, the users can approach the ODR mechanism, which uses methods such as negotiation, mediation, conciliation, and arbitration between the parties to reach a decision.”
  4. Resolution through legal remedies: The final recourse for the complainant is to explore other legal remedies available to them.

These are the questions for consultation:

  • What, if any, are the gaps or issues in the proposed Grievance Redressal mechanism?
  • What should the timelines for resolution of grievances at each of the levels – Level 1 and Level 2?

Miscellaneous questions added in the paper for comments/feedback:

  • What kind of data should the UHI dashboard provide to cultivate transparency and trust?
  • Should there be network-wide guidelines for scoring? If yes, how should it look?
  • What mechanisms should be put in place to avoid/remove fake reviews and scores? What other miscellaneous elements should be considered or taken into account, in addition to those that have been mentioned here?
  • What are some of the ways to level the playing field between start-ups and established network participants in the health-tech sector?

This post is released under a CC-BY-SA 4.0 license. Please feel free to republish on your site, with attribution and a link. Adaptation and rewriting, though allowed, should be true to the original.

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Curious about the intersection of technology with education, caste and welfare rights. For story tips, please feel free to reach out at sarasvati@medianama.com

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