Stakeholders Comments on HFR Consultation paper


S. No. Name Organisation Remarks/Feedback Attachments (if any) Comment Source
1. Prashant Satpute Satpute Architects Kindly do the needful to add all the people of rural area in this scheme. Webinar
2. Prashant Satpute Satpute Architects Kindly use mobile number for this scheme instead of Aadhar card number Webinar
3. Akhil Draksharapu Satpute Architects Kindly use mobile number for this scheme instead of Aadhar card number Webinar
4. Anonymous Attendee NA How will, having two separate registries for Healthcare Professionals and Healthcare Facilities, help ? Webinar
5. Raunaq pradhan Bajaj Finserv they should be linked by a mapping ID Webinar
6. MIS NHM ASSAM National Health Mission Sir, there should be provision to change the type of health facility.If one Primary Health Centre (PHC) is upgraded to Community Health Centre (CHC), then there should be provision to upgrade the facility. Similarly, one DH may be upgraded to Medical College.One more important point is to track the timeline. That means when the facility is upgraded.These facilities are not available in HMIS of MoHFW and creates lots of confusion and data discrepency. Webinar
7. revathy Philips Thank you NDHM Team for detailed walkthru. Very helpful. Few questions: Webinar
8. Raunaq pradhan Bajaj Finserv Health Facility Registry: Hospitals/ Labs: Name, Entity ID, Pin Code and Rohini ID (for hospitals) [Used for dedupe]- cannot be updated. Other data can be updated. Clinics: Name, Pin Code Health Facility Verifier: 1. Could be implemented as a maker-checker module. 2. Different logins could be implemented for verifier module and the data entry module. 3. Dr puts a request to link to the hospital/ clinic ID. 4. Clinic admin/ hospital admin checks the information, approves the request and that is how linking happens. Webinar
9. Anonymous Attendee NA Registries increase trust in the system. Each registry has a specific purpose and while they can be linked, they cannot be substituted by another. Ex Uber has a registry of uber drivers and that of customers. In case of HPR and HFR, use case is insurance claims, telemedicine where the registries do away with incurring costs to verify the professional and the facility Webinar
10. Mrs. K.S Bharati, INC Indian Nursing Council If the system is already existing then why not integrate the same instead of using a new platform. Nurse registering tracking system is available since 2017 and more than 10 lakhs nurses are enrolled which is a verified data Webinar
11. revathy Philips 1. Define facility - as there will be mobile care delivery units as well. In such scenario the parent enity will be registred as part of HFRs? How will be the mobile care services delivery units handled as part of this registry? Webinar
12. revathy Philips Thank you Praveen Sir. Will send out more information on it. The backgroud for mobile services was due to the emergence of mobile ICUs during covid times. point taken on the "trust" factor. Webinar
13. revathy Philips 2. We also have private ambulatory care services and emergency channels. Will the conecpt of HFR registration be applicable to them? Webinar
14. Monica NA Why only Allopathic Facilities Excluding Ayush health care providers makes the registry incomplete. Webinar
15. Krishan Access Health International The verification of facilities in HFR should be entrusted with National , state and district level councils for clinical establishment Act and openAPIs should be published which could be integrated with various councils and authorities managing the registration of clinical establishments. Webinar
16. Shirish (Prayas) Prayas After the registry is built, can these data be made available to researchers for analysis? Webinar
17. Anonymous Attendee NA There is a diffence between database (many exist) and registries which through digital identification empower the professional (nurse/ doctor) to use it to authenticate digitally (insurance claims, telemedicine eprescriptions etc Webinar
18. Yochan-Piramal Swasthya Piramal Swasthya when will health facility registration be open to all of india ? currently we see its open only for union teritories Webinar
19. Monica NA To have a complete registry, the process of registering should be Mandatory for all Health Care Facilities. The mandatory fields in Annexure 1 that you have proposed are minimal. The details may be kept voluntary Webinar
20. Special Sec I.T. & E. GoUP Government of UP will this be made mandatory with legal sanctity as well? Webinar
21. Monica NA What about organizations which are involved solely in Health Care Research not necessarily Clinical Trials Webinar
22. Dr. Arya Patel NA To use data of HFR for data analysis and research.......... there should be concent taken from the patient. This is my suggestion. Webinar
23. Krishan Access Health International clinical establishments act 2012 provides for two types of registration - provisional and parmanent No enquiry is done at time of provisional registration and parmanent registration is done after notification of minimum standards by clinical establishments. The workflow for HFR registration should be aligned with clinicalestablishment act and a lagislation should be brought in to apply clinical establishment act for all states and UTs. HFR design should be aligned with clinical establishment act. Webinar
24. Anonymous Attendee NA While data may be taken from existing databased the entitities (Professionals and facilities) will have to create a digital identity. Database will serve to verify your certification to practice but Digital identity will open up opportunities for the entity Webinar
25. Prashant Satpute Satpute Architects what measures you have integrated in system to prevent malpractice doing by some doctors and hospitals Webinar
26. Manisha Bajoria IIT Delhi Why would I be interseted to enroll onto HFR? What benefits indirecly will a stakeholder get after enrolment? Webinar
27. revathy Indraprastha Institute of Information Technology, Delhi Will there be linkage Interfaces as part of NDHM backbone between HPRs and HFRs , as an NDHM implementor , there could be workflows where a patient can look-up for specific care providers and implementor may need to provide the care provider associated facilities / nearest care providers etc. Scenarios can be innumerable. I believe thats the direction we intend to head.Thougts pls on simplfying integration points for implementors? Webinar
28. Bhaskar Dabhi (Plus91) Plus 91 Will Health Facilty get HIP / HIU ID when they get enrolled in the registory or that will be a different process? Webinar
29. Natarajan Ravichandran Palm Power will the database be searchable using APIs? for example can I search for list of hospitals having cardiology speciality having PMJAY enrollment near a given geolocation? Webinar
30. Krishan Access Health International NHRR has already compiled data of a large number of facilities. would that also need verification in HFR? Webinar
31. Dr Chiranjeevi Dixit CAD CARE Team NDHM, I have suggestions on following points 1. Row no 860 in annexure 2 in support services - I would recommend to include SNOMED CT 2. Also include the same for HPR registry so that it goes in sync with HFE globally 3. Please include FHIR device recourse from L3 of FHR R4 4. By adding device resource, devices like pulse oximetry can immediately connected across HFR from HIU 5. This will be great help in handling COVID situation Webinar
32. Anonymous Attendee NA Digital audit trail will help identify fraud by doctors and hospitals -Ex insurance claims put in the name of one doctor for multiple operations across multple facilities if on paper are difficult to catch, while digital data catches it effortlessly Webinar
33. Niraj Garg Siemens Healthineers A general comment - I feel the goal of this program should be facilitate seamless flow of data in a patient-centric manner - first and foremost, instead of diluting the concept to improve 'ease of doing business' - this could be looked at in the later phases of the program Webinar
34. Krishan Access Health International Facilities data in all international counteries come in category of public data set why consent is required to acces it? Also when facility ID verification is required as lookup API in HIE transactions , how consent by facility manager wil fit in workflow and how it will impact the transactional flow in HIE? Webinar
35. Dr Pankaj Gupta Access Health International Health Facility Varifier [HFV] runs the risk of bringing Vigillance and License Raj. It is best to empower the District Health Officer to be the Nodal Officers responsible for the HFR data accuracy in their own District. Webinar
36. Syed Quasim Ali - Practo Practo The premise and core of NDHM is to use technology and digitization for providing accessablity to quality healthcare, and to add value to the existing healthcare ecosystem of the country. We have talked about the registry of healthcare professionals and healthcare facilities. But, there is no clarity of how to register and integrate the digital healthcare companies with NDHM, that are providing integrated healthcare services like telemedicine, e-Diagnostics, e-Pharmacy, and healthcare information. It would be very helpful if you could pls. provide clarity on how to integrate/register the digital healthcare companies with NDHM Webinar
37. Manisha Bajoria Indraprastha Institute of Information Technology, Delhi Not every stakeholder has experience in digitization.In order to make those stakeholders register,firstly, that category(which is large in number) should be informed in personal(seminars/presentation) in order to make them understand and secondly, some of the benefits/pros can be proposed which makes them voluntarily available for registration. In this regard, State govt. might help in reaching out those stakeholders. Webinar
38. Dr Chiranjeevi Dixit CAD CARE Do define facility, we need to define Service FHIR L3 health care service, device & Organisation Which are not included at this point in corresponding FHIR resources in NDHM. Webinar
39. Manvendra Dubey KareExpert I am Manvendra Dubey from Karexpert how data will flow with diffrent digital players. Webinar
40. Ajeet Kumar Singh NA Can the data will be avilable for the public health researchers ? Webinar
41. Amarjeet Cheema NA Ais blood bank categorised as a doagnostic center or pharmacy or seperate entity as a blood bank Webinar
42. Sujeet Katiyar CCKC Ltd. Are you going to list cases of Malpractices and Med Legal cases against facilities in HFR and keep on updating the same in future as and when required? Sujeet Katiyar Webinar
43. Neha (Product Manager, Piramal Swasthya) Piramal Swasthya We can also look at including: 1. hospitals/institutions which are providing palliative care for terminal illnesses or senior citizens. Generally these centres do not have doctors aligned to them permanently, they visit them on need basis. 2.vaccination centres 3. make-shift/temporary care centres setup for pandemics or in case of natural disasters 4. partial hospitalisation programs (with visiting doctors) 5. rehab centres (with visiting doctors) Webinar
44. Anonymous Attendee NA How are the graduate optometrist and ophthalmic assistant will be enrolled in facility register. they are working in primary eye care in vision centres associated with eye hospitals, eyewear retail, eye hospitals, some are also into private practice, optical shops. Webinar
45. revathy Philips One important point to consider when using FHIR. R4 of FHIR is Mixed Normative. There are FHIR resources which are still draft.Will the implmentors of NDHM forced to upgrade when these become normative. This question is not in context of HFR but general. okay if we can pick as part of UHI webinar. Webinar
46. Nirmla Thakur NA System like Ethics committee in Central Drugs Standard Control Organization can play a role in audit/verfication of health care facility Webinar
47. Anonymous Attendee NA Which is the central body in India which regulates health facilities (like NMC for doctors)? Webinar
48. S L Megha Health Insurance Scheme Would like to suggest to please ask the Number Plate of Ambulance when entering into the HFR, like wise the Model Number of Machine like MRI, X-ray, CT Scan machine. So this will reduce the hospital in giving wrong information. Thanking you. Webinar
49. Raunaq pradhan Bajaj Finserv The network could be two pronged. For smaller clinics- which are operated by doctors, the dedupe could be simpler - using MCI-ID/ unique email ID. For mapping doctors mapped to hospitals- it could be regulated by the admin at the hospital (with a dedupe logic) at place. We have built together this model in place with dedupe logics between hospital and clinic onboarding to be handled separately for 50k+ hospitals. Webinar
50. Dr Chiranjeevi CAD CARE NDHM Team, Good work going, We’re being working on FHIR R4 since 4 years and being tracking National Health Policy 2017, there was one clause about MoHFW owns IPR, can I know who owns the IPR - Intellectual Property Rights over the health care data in your Sandbox Since we’re also working with NHS UK, NHS UK Supply Chain framework clearly says that the IPRs are owned by NHS UK and Technology provider Webinar
51. Dr Pankaj Gupta Access Health International Some scenarios to think about.. 1. Lots of Medical Specializations are not listed in India's MCI/NMC e.g. Fetal-Medicine, Pediatric-Cardiology. How to deal with that? 2. BDS is not allowed to do MD/MS courses in India but similar specialisation is allowed outside India. How to deal with such issues? 3. MCI/NMC does not recognise Specialisations in many Non-Clinical areas e.g. Genetics and Bioinformatics. How to deal with that? Webinar
51. Laurie Hawkins AITIA Global Have been responisible for the adoption of the National Health Services Library (National Health Services Directory) in Australia, used by 8 state/territory governments plus the federal government and 1000's of health provider organisations including public, private and not for profit and is the "Single Source of Truth" for health and social care It has over 400,000 services, is the registry for the 300,000 accredited healthcare professionals, over 14 million transactions/month and operational since July 2012 building upon the success of the Victorian Human Services Directory This data is used by the National Healthmap for advanced visual data analytics together with 1000's of other datasets View Website
52. Kumar Narottam Onsurity Technologies Private Limited 1) Concern: "Infrastructural gaps" for remote locations Suggestion: For data collections, we should create form based application which writes data to local database (eg: SQLLite) within the machine and every 15 days it is bound to sync back to main server. We should follow master slave approach for data collection here. Form based application will be created by NHDM (self or contracted). The application will be cloned to multiple machines and every machine will be given a unique key to identify itself in ecosystem. This machine would be movable without internet and remote area data collection would be easy stuff. I understand this is very brief introduction to this approach but upon agreement this can be elaborated further. 2) Concern : Data protection and privacy Suggestion: We should go for 2 factor privacy. Any one who want to sync data with master server will need to key agent machine key and OTP on registered mobile number of agent. Data fetch will be done only based on rest API's and API would be secured using API key and expiring token methodology. Data fetch in a day can also be limited like 1000 calls per day. 3) There are no quick incentives for someone to enrol, India is very big demographical country. To maintain the intensity of data collection we should drive this by some quick incentives who register themselves on HPR platform. 4) As India is a very big demographical country and HFR is trying to take diversified data collection approach. This needs to be strengthened by laying a schema of fields to be collected. Or better is create a tool which is form based and does not require internet to run in remote locations. Or Even data collection should be made possible in mobile apps. Data should be extracted out in excel and later synced to main server. Website
53. Sivani Peesapati Onsurity Technologies Private Limited 1) Concern: “Infrastructural gaps” for remote locations Suggestion: For data collections, we should create form based application which writes data to local database (eg: SQLLite) within the machine and every 15 days it is bound to sync back to main server. We should follow master slave approach for data collection here. Form based application will be created by NHDM (self or contracted). The application will be cloned to multiple machines and every machine will be given a unique key to identify itself in ecosystem. This machine would be movable without internet and remote area data collection would be easy stuff. I understand this is very brief introduction to this approach but upon agreement this can be elaborated further. 2) Concern : Data protection and privacy Suggestion: We should go for 2 factor privacy. Any one who want to sync data with master server will need to key agent machine key and OTP on registered mobile number of agent. Data fetch will be done only based on rest API’s and API would be secured using API key and expiring token methodology. Data fetch in a day can also be limited like 1000 calls per day. 3) There are no quick incentives for someone to enrol, India is very big demographical country. To maintain the intensity of data collection we should drive this by some quick incentives who register themselves on HPR platform. 4) As India is a very big demographical country and HFR is trying to take diversified data collection approach. This needs to be strengthened by laying a schema of fields to be collected. Or better is create a tool which is form based and does not require internet to run in remote locations. Or Even data collection should be made possible in mobile apps. Data should be extracted out in excel and later synced to main server. Webinar
54. Niraj Garg Siemens Healthineers Thank you for providing us this opportunity, Kindly find enclosed our suggestions with reference to the HFR and HPR papers. Our suggestions are based on a single registry that conforms to the IHE (Integrating the Health Enterprise) standards. View Webinar
55. Niraj Garg Siemens Healthineers Thank you for organising this interaction - we are a Global Medtech IT MNC who have implemented ehealth infrastructure projects in Switzerland, Austria and are implementing this in Chile currently. We would like to be associated with this program, by sharing our expertise in this topic. Our eHealth solutions is fully compliant with data protection requirements and relevant, international interoperability standards such as: • Integrating the Healthcare Enterprise (IHE) • Health Level 7 (HL7) • Fast Healthcare Interoperability Resources (FHIR) • Digital Imaging and Communication in Medicine Webinar
56. Nitthin Chandran Medpiper Comments attached in the file View Webinar
57. Dr. Atul Mohan Kochhar -CEO, NABH National Accreditation Board for Hospitals & Healthcare Providers comments from NABH-QCI on "Consultative Paper on Health Facility Registry under NHA". File attached View Webinar
58. Sachindev CHC and Refferal government hospital Physiotherapy upgradation View Website
59. Hardik Bhatt Gujarat Government Physiotherapist Association Suggestions for Consultation Paper on Health Facility Registry(HFR) For clause 2.1 one good example of digital registration and working is Gujarat State Council For Physiotherapist (GSCPT) ,which is regulatory body for physiotherapist in Gujarat even member register is online.(GSCPT) For clause 2.3.1 ,among various international models we suggest to follow U.K model of central data, paperless prescription and e-referral. If its difficult to do at national level maintain at state level. In clause 3.2 in data schema add patient feedback/experience as new category. There should be cross verification weather patient has received from healthcare premise. It will work not only as client service provider feedback but also as guidance for future patients seeking same treatment from same premise. In clause 3.2.1 Minimum HFR data in appendix 1 for physiotherapy first option is Physical Medicine & Rehabilitation (PMR)/ Physiotherapy, suggestion is to keep physiotherapy only as both are different and keeping both in option is irrelevant In clause 3.2.1 Minimum HFR data in appendix 1 for physiotherapy we suggest to add few more points Chest Physiotherapy Gait Training Fitness Training Rehabilitation Geriatric Physiotherapy Paediatric Physiotherapy In appendix 1 type of facility there is option of Physiotherapy Clinic, We suggest to replace the term with Physiotherapy & Rehabilitation Clinic. As all Physiotherapy clinics train for Rehabilitation and its most commonly uses terminology used by physiotherapy clinics. In appendix 2 we suggest you to add Physiotherapy Clinic & Hospital option in Type of Establishment like for dentistry, as per in other area dentistry and physiotherapy both are mentioned separately in the paper. In clause 3.2.2 under 1) Licensing authority we suggest to add various healthcare regulatory bodies of central government and state like in Gujarat for physiotherapist manpower Gujarat State Council For Physiotherapist. For clause 3.3.3 and 3.3.7 we suggest to alternative 1 for HFR verifier. We suggest to give priority to boards/commissions/councils as verifiers who already registering and maintaining standards of HealthCare professional Gujarat State Council For Physiotherapy may work as verifier for Physiotherapy clinics and hospitals. Website
60. Manish Kapoor Amazon Internet Services Private Limited Thank you!. View Website
61. Revathy Sreenath Philips Thank you for a detailed paper. Pls find the comments attached in the pdf document uploaded. View Website
62. Rohin Garg Internet Freedom Foundation Analysing the NDHM Health Data Management Policy View Email