Stakeholders Comments on HPR Consultation paper

S. No. Name Organisation Remarks/Feedback Attachments(if any) Comment Source
1. Dr. Mayank Agarwal,Agra, India Harvard University HPR in Jan Aushadhi Kendra ? - In case a doctor is running a Pradhanmantri Jan Aushadhi Kendra, which is licensed in the name of BPPI. Who will get the HPR here in this case, The doctor running the PMBJP or BPPI ? Webinar
2. Akhil Draksharapu NA how open is NHA and NDHM to partner with startups and integrating and bringing Interoperability? Webinar
3. Dr. Mayank Agarwal,Agra, India Harvard University Patient Centricity is missing from NDHM Principles Webinar
4. Kumar Narottam Onsurity Technologies Private Limited How are we collecting information, is there a portal to submitt this information? If yes, how are we going to capture data at non internet demographic areas of India? Webinar
5. Dr Pramod Jacob NA One of The main issue maybe the shared responsibilty of populating ,maintaining and updating of the registry by the various councils , regulatory bodies and stake holders involved. Has fairly extensive dicussions with bodies such as State Medical Councils been held and have they been enlightened on the processes and responsibilities that they are responsible for ? If so what has been their response ?- Thanks, Dr Pramod Jacob Webinar
6. Santhosh Babu NA Is Blockchain technology being used to establish the 'single source of truth' of this registry? I seriously suggest that you should. Webinar
7. Dr. Mayank Agarwal,Agra, India Harvard University Will a Data entry operator in a NDHM compliant Healthcare facility qualify for HPR ? Webinar
8. Santhosh Babu NA Is Blockchain technology being used to establish the 'single source of truth' of this registry? I seriously suggest that you should. Dr.Santhosh Babu IAS (VRS), Former Principal Secretary IT, Government of Tami Nadu Webinar
9. nita Ispirit It should be pointed out that this is a Live repository Webinar
10. Dr. Mayank Agarwal,Agra, India. Harvard University Will HPR provenance for a doctor include foreign training also ? Webinar
11. Dr. Soubhagya Sagar Behera Rodic Consultants Pvt Ltd Anmol has been launched extensively in many states. That should have a registry of ANMs? Webinar
12. Ankit Mittal NA Who all will be allowed access to this registry? Is the Access to this registry going to be governed by a legally enforceable regulation? Webinar
13. Dr. Akhil Malhotra ThoughtWorks Can a professional register under more than 1 roles? For example: A doctor could also be a researcher. Webinar
14. Shirish (Prayas) Prayas Are counsellors and psychotherapist considered as healthcare professtional Webinar
15. Raunaq pradhan Bajaj Finserv 1. Do we have visibility of using MCI no to do validation instead of Aadhar? 2. For this to work at scale, and for health-tech providers to do mass validation, can we look at other de-dupe logics beyond Aadhar/ MCI no? Webinar
16. Abhilash Chakraverty NA Will the doctors registry in IMA be dissolved or automatically migrated to HPR ? Webinar
17. Dr. Mayank Agarwal,Agra, India Harvard University HHPR should be related to Clinical and health related professionals. Data entry operators and social workers and survey are indirectly linked so they must be categorized in another Webinar
18. Sujeet Katiyar CCKC Ltd. Why registration in HPR is voluntary? In my opinion it should be mandatory so that there should be correct data analysis for any scheme or any other purpose. Regards, Sujeet Katiyar Webinar
19. nita Ispirit To decide who all HPR should be extended to arethe body of that profession Webinar
20. shivangirai NA Q) enrolment is voluntary. However, if doctors dont enrol, will they be able to provide telemedicine services? This is important because mandatory enrolment in NDHM is not mandated by law, so can it exclude doctors from digital health services, which they are otherwise entitled to provide? Also, enrolment is voluntary, but is there anything which prevents a hospital to mandate its doctors to enrol? Or if the health facility itself gets an Id, will doctors working there, be required to get one too? Webinar
21. Aravamudan Wipro Is the HPR vision inclusive of Data Storage/IT professionals who are involved in the Health Care Ecosystem ? For example FHIR includes IT teams involved in the delivery of the HealthCare IT services Webinar
22. nita Ispirit 1) there is a governing body to verify 2) what value does the ecosystem get from that HP Webinar
23. shivangirai NA Also, if it’s voluntary, is there an informed consent form? Webinar
24. Uma nambiar NA Also, if it’s voluntary, is there an informed consent form? Webinar
25. Bharat Gera NA Bharat Gera, Founder, Human Centric Health Ecosystem and ex CIO, St John's National Academy of Health Sciences. Have you considered the model of American Board of Medical Specialities - did not see it mentioned in the consultation paper. Webinar
26. Abhilash Chakraverty NA ecosystem model should be followed . this should include all professionals working in the healthcare establishments , pharmaceutical and medical devices companies and suppliers to hospitals also Webinar
27. Neha (Product Manager, Piramal Swasthya) Piramal Swasthya 1. What are the data security guidelines around maintaining professional registry? Webinar
28. Anonymous Attendee NA we are into medical devices manufacturing business and provide screening facility as service to our clients. do we need to register our operator who do the screening under HPR ?? Webinar
29. Sujeet Katiyar CCKC Ltd. wWe should follow Eco centric model for HPR. Sujeet Katiyar Webinar
30. Dr. Mayank Agarwal,Agra, India Harvard University wHPR Governance - Federated Model Webinar
31. Dr. Mayank Agarwal,Agra, India Harvard University Please see Harvard Radcliffe report on exchangig Health Information in India including concept of Intermediaries. Webinar
32. Uma nambiar NA The best way to collect data is to take the list of people.xlearing all exams from all.insriturions.let them upload the data and each person passing out will get the HPR number after passing the exams... Uma nambiar Webinar
33. Neha (Product Manager, Piramal Swasthya) Piramal Swasthya 2. How frequently would the data be updated for healthcare professionals and how would the updates be made? (e.g. A healthcare professional has a complaint recorded in the official records, how do we record that?) Webinar
34. Abhisar Bhatnagar CONSULT VERRATON LLP I feel tier'd centralized model would suit. Also what are NDHM's vision of usage of Machine Learning and Artificial Intelligence to filter and process First Point of Entry of Data? Webinar
35. nita Ispirit Intended Role of GOI to accelerate adoption of Professional Registry • Declares Doctor Registry as the single window for doctors to avail any services off NMC or State Medical Councils • Maintains the Doctor Registry Schema and defines role-based access rights. • Sets up rules of validation of data, SLAs for all actors/ validators in the ecosystem and manages consequences only. • Provide APIs and catalyze market participation to create ideal grounds for the interplay of public utility and private innovation. • Mandates all public/private players (Health Tech/ Care Intermediaries/ hospitals/ medical educational institutes / Insurance etc etc) to enroll only registered doctors and in case of any disputes, liability will be in proportion to the transparent validation status in the registry Webinar
36. Dr Pramod Jacob NA Would suggest that both patient centric and ecosystem centric may have to be included in the registry - maybe in different sections . For example - the billing department /finance department staff have a large role to play in a patient's experience of a healthcare enounter/s . At the same time clear crystalization of which are the roles in healthcare ecosystem will have to be worked out Webinar
37. Dr. Soubhagya Sagar Behera Rodic Consultants Pvt Ltd I will formally include this as a comment on the portal, but the entire phase 1 vaccination drive was for all healthcare professionals, it was not limited to doctors, nurses and included everyone in the hospital. Leaving limitations aside, it still has the most updated list of HCW as of 2021. That is a list that can be checked. Webinar
38. Bharat Gera NA Bharat Gera, Founder, Human Centric Health Ecosystem and ex CIO St John's. Is it possible to keep identity and access aspect distinct from credentialling? NDHM can ensure that identity is verified centrally and maintained in decentralized registries kept by states. Webinar
39. Aravamudan Wipro The role of HPR wrt IT teams included as FHIR resource will also help in Correlation and Data Analytics . For example , healthcare @home services can be done through Mobile Apps , and the app developer(even individual) provides a healthy platform and can be registered in the HPR. Webinar
40. Rishabh Trivedi Narayana Health Where can the consultation paper be accessed from. Can you provide the document/link for the same? Webinar
41. Dr. Mayank Agarwal,Agra, India Harvard University Handholding doctors - Who will do that? State Government ( Who might not have the Health IT workers ) or STartUps ( WHo might struggle with credibility issues ). Any PPP ? Webinar
42. Chiamala cSoft Technologies Who will have access to this data, and how is it planned to be utilized ? Webinar
43. Rakesh NA WHow to filter fradulent Dr or Paramedic? Webinar
44. Rakesh NA This unique ID for health professional will be superceding to MCI or can they use it for some other works? Webinar
45. Secty; Dr. A.K. Singh, Jharkhand SMC Jharkhand Medical Council how is this going to help doctors so that they volinteer for registration? Webinar
46. Rakesh NA How technical integration will be maintained? And How data leakage will be prevented? Webinar
47. Uma nambiar NA the doctors have so many issues with current registries, that they might be happy to have something simple like HPR. I think simplicity of the solution will be the biggest incentive....Uma nambiar Webinar
48. Dr. Mayank Agarwal,Agra, India Harvard University Please consider incentivise doctors for onboarding NDHM by 1. Computer print out of prescription which will have Drug Drug Interaction clearance. This will give much credibility to the doctor amongst patient. And will address the issue of DOctor and Chemist duo . Webinar
49. Dr Sudha Kodati NA "Incentivization - means what advantage or what benefits would doctors have by registering to this platform? How will you encourage the doctors to register? Webinar
50. Arun MK, NA is this means doctor/health workers will be a getting an unique id... is it going to be a part of PHR Webinar
51. Abhisar Bhatnagar CONSULT VERRATON LLP Suggestion: Suggested process flow of HPR: 1. HP registers at Point of contact. 2. The HRP will request all relevent HP documents 3. AI and ML enabled NDHM APIs would forward document to relevant authorities Webinar
52. Dr Sudha Kodati NA 2early adoptors" - should also have some benefits - could be some CME points...or some sort of benefits to dcotors Webinar
53. Dr Sudha Kodati NA how to regir those doctors who are part timers in some hospitals or a single doctor working in several institute Webinar
54. Dr. Mayank Agarwal,Agra, India Harvard University NHA can include few BEACON COMMUNITIES , Early Vanguard of NDHM, so that startups, hitech hospitals, newer hospitals can get a sense of basic IT and Informatics infostructure to onboard Webinar
55. Singh V NA For Yoga, we now have a Yoga Certification Board of India… It can be used for Yoga certifications… Webinar
56. Swapnil NA I think the participation of Doctors and other health professionals should be mandatory to avoid the conflict of Linkage between HPR and HFR and this can be done by incentivising professionals. But data share of HPR to other entities can be made consent based using DEPA framework. That will make sure that the Data is not getting shared to anyone. Webinar
57. Neha (Product Manager, Piramal Swasthya) Piramal Swasthya The Paper mentions "a slave database that will be kept synchronized with the master database." Will this be real time? Or will this be done at regular periods of time? Webinar
58. Prakhya Solutions Prakhya Solutions This is wonderful program and certaily futuristic. Following are my views - 1. Implementation should be centralised at state or center level even though it may lead to operational challenges. 2. It would be good if NDHM can ensure that each institute and council builds the internal registry for validation. 3. Patient-centric approach would be good to maintain HPR 4. It may be good to limit the registry for doctors and nurses to start with, rather than complicating registry with other professionals like Ashas, Ward boys, Supporting staff, etc…. Webinar
59. Dr. Mayank Agarwal,Agra, India Harvard University Since when do u plan to issue HPID? Will it be a Credit Card size PVC Card ? or Digital ID like @ndhm health ID? Webinar
60. Registrar NA what about secrecy of data and that data should not be misused Webinar
61. Janak Shah Wadhwani AI Will there be a linkage to insurance cover, pricing for doctors charges which the govt may mandate like price ceiling for stents, and other such measures which could prove to be a disincentive for doctors to register? Conversely, can we say it might prove to be an incentive for HP to register to get recognised for insurance or other beneifits? Webinar
62. GM-MIS NA Why don't we apply HPR as part of various healthcare professtional registration process ? Webinar
63. Dr. Mayank Agarwal,Agra, India Harvard University UP STate MEdical COuncil issues chip based Medical COuncil registration PVC CArds. NHA can simply demonstrate interoperability and all UP MC will need to do is add one line containing HPID or the doctor who just registered with Medical COuncil Webinar
64. Bharat Gera NA Most important thing in healthcare is to establish trust between patient and health professional, not everyone in the team has to be verified as long as the health professional responsible for care is trusted. Rest of the team can be implied trust to begin, otherwise it will be quite a challenge to get every health professional on board the NDHM Webinar
65. Santhosh Babu NA The NDHM database would allow us to move to predictive health care Webinar
66. Prakhya Solutions Prakhya Solutions My question is more on maintenance of registry, since the employment is part of the registry…how would that employment be verified as doctor’s as every other hospital may not be digitalised. It may be good enough to validate education and certification….why would HPR need to have employment details? Please suggest if i am missing something…. Webinar
67. Tanay Surkund Prescrip Can digital health companies act as a defacto portal where we collect the requisite data from the doctors(users of the software) and submit it and assist them in getting their HPR ID? Webinar
68. Dr. Mayank Agarwal,Agra, India Harvard University incentivize doctors to onboard HPR - Free MS Office software suit if doctor onboards NDHM Webinar
69. Madhu Nano Health This is Madhu from NanoHealth, a digital health platform provider. Where will the data be stored? In NHA central server or in digital systems like ours? Webinar
70. Dr. Mayank Agarwal,Agra, India Harvard University For patient Centricity pleasse see PCMH model of US "The Patient-Centered Medical Home (PCMH) is a care delivery model whereby patient treatment is coordinated through their primary care physician to ensure they receive the necessary care when and where they need it, in a manner they can understand." Webinar
71. Dr. Mayank Agarwal,Agra, India Harvard University This model of Patient Centricity - Click Here Webinar
72. Prakhya Solutions Prakhya Solutions Can digital health company or hospital confirm on healthcare professional certificate and issue HPID using APIs given by NDHM? If yes, how do you ensure correctness of the data? Webinar
73. Prakhya Solutions Prakhya Solutions Does NDHM own HPR registry OR can there by multiple HPR vendors who provides the registry for digitl health solutions? Webinar
74. Secty; Dr. A.K. Singh, Jharkhand SMC Jharkhand Medical Council In indian medical register all the details of doctors are available. why not reinforce it further for updating. Webinar
75. Dr. Mayank Agarwal,Agra, India Harvard University NHA and NDHM can posts a Rolling Curtain of INFORMATI-Quotes, sourced from global health systems engineers. One such quote is appended " "The Business of Medicine (BOM) is not the enemy. It's the solution when done as entrepreneurial altruism, not cronie capitalism. People banding together in organizational structures to realign asset and capital investments focused on higher awareness within the body of pending diseases and emergent events is fruitful. Supporting communities of care and just following the fruit of the human imagers' spirit remains the strongest and most compelling force for good change in a world hostile to the immune system. Group Health Cooperative is one such organizational model that's been held up as "best practice." - John Hoben, Energy Benefit Group, LLC Board of Directors, Society for Participatory Medicine" Webinar
76. anushka Medianama Please elaborate on the prospective incentive for enrolment into the HPR Webinar
77. Ajit Sinha Health Compass In case of lady doctors, in most of the cases, surname change after marriage. How do you authenticate with Aadhaar? Webinar
78. Sumesh Singh COIT NA Dear Sir, First of all Many Congratulations to the NHA Team. My suggestion is to associate atleast one technical person for support and guidance. Regards SUMESH SINGH NHM RAJASTHAN Webinar
79. Bharat Gera NA How about keeping it voluntary and yet allow patients to request validation of HCP - just a suggestion to make it demand led. Bharat Gera Webinar
80. Salil Kallianpur NA When there is Aadhar registration done, will it not be easier to pull out data froM there? Why a new HPID again? Will the two be linked eventually like Aadhar linked to PAN Card? Webinar
81. Neha (Product Manager, Piramal Swasthya) Piramal Swasthya Do we also plan to have an assisted mode of registration as well - especially for FLWs like ASHAs, ASHA facilitators, etc. Webinar
82. MK NA Is it not right to mandatorily getting registered for all healthcare professionals who are directly involved in the treatment of the patient so that the information is verified and authenticated from various professional bodies associated with the practitioner like medical colleges, Provider facilities etc.? Webinar
83. nita Ispirit What if HPR is the single window for professionals to seek registrations and re gistrations... data to SMCs flows through HPR Webinar
84. Dr. Mayank Agarwal,Agra, India Harvard University How about NSDL and CSDL hosting NDHM Data and Registeries. People trust NSDL and CDSL with their crores of money. Having same Depositories will add Finance and Health data and will give credibility to DATA repositories! Webinar
85. Dr. Mayank Agarwal,Agra, India Harvard University Access registeries - How about Aadhar OTP system. The doctor can choose not to allow his details by simply ignoring OTP Webinar
86. nita Ispirit Incentives for doctors to keep their data updated in the HPR Saves time and energy of health professionals by skipping in person visits to councils, submission of academic credentials and furnish CME compliance when re-registering every few years, or move to a new state or when enrolling in multiple private/Govt. Insurance schemes etc, faster insurance claims through esign as verification status on the registry has potential to enhance trust for insurers, Safe access to more patients through telemedicine as it removes location barriers and contact risks (as demonstrated in Covid 19) Webinar
87. Anonymous Attendee NA How do we ensure frequent updation of data? and though what medium? Webinar
88. Manish NA Does legal cases and judgement impact on HPR and it will be updated. Will Facilities registered on NHA can access and take decision of hiring these HPR. And does patient know the Truth of HP thru HPR before going for a treatment. Webinar
89. Dr. Mayank Agarwal,Agra, India Harvard University Discoverability for doctors in itself is very big incentive.! Webinar
90. Manish NA Will these register would be accessable to facilities outside India (e.g. indian origin hospital functioning outside India and non Indian citizens) in such cases. Webinar
91. Sandhya Ahuja NA How long will it take to complete this huge exercise? Webinar
92. Sandhya Ahuja NA Has the time frame of response by MCI or other authorities been worked out ? Webinar
93. suneet singh ranawat NA Councils may have very important issues which can be resolved by interactive session with NMC authorities, secondly can there be some central agency which can visit state councils to instruct, monitor and help in collecting/maintaining a required documents related to HPR. Dr Suneet Singh Ranawat, Webinar
94. Nirmla Thakur NA If the doctor changes his hospital affiliation and does not update on the portal. How this will be addressed? Webinar
95. Md.Masoom Ali, Jharkhand, AD,ICTC, NA What will be strategy for advocy for implimentation of the programme at grassroot level Webinar
96. Dr. Akhil Malhotra ThoughtWorks HPR and HFR should be independent of each other. Doctors should not be tied to a facility. In case a patient’s medical record is recorded against their Health ID, it can be signed with the HFR ID and all the HPR IDs separately. Webinar
97. Bharat Gera NA Have we done a survey or poll with health professionals on their willingness to participate in registry? Maybe we can hear from horse's mouth on what their fears and apprehensions are about such a registry. Thanks for taking up all comments and being open. Bharat Gera Webinar
98. S L Megha Health Insurance Scheme As TMS application of PMJAY has already stored many of the empanelled Doctors details, can it be easily fetch from that Application to NDHM? Webinar
99. S L Megha Health Insurance Scheme Do register in NDHM require Aadhaar to furnish? Webinar
100. Dr. Mayank Agarwal,Agra, India Harvard University CAn we have all the panelist to introduce themselves , we can direct our suggestions and queries accordingly. Webinar
101. Dr. Mayank Agarwal,Agra, India Harvard University UHI is Health Version of UPI. How about a Youtube video on NHA youtube channel Webinar
102. HARI RAJ SINGH NA I am seeing the evolution of this model as a trendsetter for evolving registry for all professional sectors....PCI, NCI, VCI, ICAR, ICFRE and so on, to name a few..... well, are there any plans to have pyramidcal data enumiration involving all medical institutions on one side and states and UT's on the other, as health being a state subject. I think there should be a comfortable cut off date to be decided to make enrolment mandatory. Thanks! Webinar
103. Dr. Mayank Agarwal,Agra, India Harvard University What is the ultimate goal or mission of NDHM? is it achieving Precision Medicine infrastructure or Health Information Exchange or Data Analytics Webinar
105. nita Ispirit NBE can be the verifier for international doctors Webinar
106. Akhil Draksharapu NA When will NDHM come to its full fruition? what would be the likely future of NDHM Webinar
107. Kumar Narottam Onsurity Technologies Private Limited How are we collecting information, is there a portal to submitt this information? If yes, how are we going to capture data at non internet demographic areas of India? Webinar
108. shashi Gogia NA What happens when someone else is already registered at the NMC portal with your registration number? Webinar
109. suneet singh ranawat NA HPR should not be for foreign graduate. Webinar
110. Dr. Mayank Agarwal,Agra, India Harvard University Suggestion - Android Telemedicine can interoperate with APple or MSFT app ... SMARTonFHIR App platform is very democratic. It provides a substitutable environmen Webinar
111. Nirmla Thakur NA Whether patient consent will be taken before displaying his/her history on the portal? As some patients might not be comfortable with this idea Webinar
112. shashi Gogia NA I have applied in the sandbox, but no reply while the DMC carries my DMC number 11091 in another persons name Webinar
113. Dhruv Suyamprakasam icliniq Hi, There is this alliance called ‘Synaptic health alliance’ in US. Their whitepaper addresses a similar thing and lot of things from there can be used for this., Dhruv Suyamprakasam, CEO, iCliniq Webinar
114. rohit Universal MedNet Unless registeration is made mandatory how the adoption will be encouraged. is there any other direct incentive offered. Implied benifits will take time to surface, by then it might be too late. Please make this mandatory or announce incentive fpr adoption. Webinar
115. Akhil Draksharapu NA which startups and companies has NDHM already in collaboration? Webinar
116. Dhruv Suyamprakasam icliniq Yes. The flow is clearly here with this document —> I have read it thoroughly and probably need to talk with you about my views. Dhruv, iCliniq Webinar
117. Dr. Mayank Agarwal,Agra, India Harvard University Suggestion - NIA monitors every project using Blockchain because of their role in error financing. NHA can issue some alert guidlines on it. ! for startup community Webinar
118. rohit Universal MedNet It wont solve the purpose if few Doctors have volunteraly registerd only. Every new innitiative faces reluctance,. Instead of voluntary regisration. Data should flow from MCA directly and autmatic registration shpuld happen. This will save the resistance to make an effort to register Webinar
119. Dr. Akhil Malhotra ThoughtWorks I understand that blockchain needs a lot of computing power. To use it or not should also be properly evaluated for investment vs. benefit. Webinar
120. Neha (Product Manager, Piramal Swasthya) Piramal Swasthya Can we also look at accomodating data around applications that a doctor is currently available on - Practo, 1mg, etc. so that it helps in building OHSN and in turn aid build interoperable telemedicine platforms. Webinar
121. Sudarshan Vadyar NA During registration, HPR will validate the licence of a doctor / health professional. but after registration and after few years if the doctor's license is revoked (may be a rare happening) by concerned authority / council, how does the HPR handle this ? Webinar
122. Dr. Mayank Agarwal,Agra, India Harvard University SUggestion - US legacy Health Information Systems were too powerful to facilitate a Patient Centered Health Economy, still Big NAmes are trying to open up API sensing the shift from PAternalistic Healthcare to Participatory Healthcare. NDHM has once in a lifetime opportunity to demonstrate to US and UK alike. There are many in US who highly look forwards to NHA- NDHM to address US healthcare woes. Our Aadhaar is our pride . I can see NDHM heading as another Webinar
123. CAD CARE NA Team NDHM I Recommend blockchain is not required Dr Chiranjeevidixit Webinar
124. Dr. Mayank Agarwal,Agra, India Harvard University Suggestion - NDHM USe CAse - The biggest frustation of patients is dealing with megalomaniac personal assistants of doctors. NDHM can addres this issue very well. It will save crowding, noise pollution and unnecessary human interaction a lot. PRomises of Digital Health which untangles the complicated Patient Physician interaction will be widely adopted Webinar
125. CAD CARE NA Since, the blockchain comes to picture only when there is lack of trust and and medicine is all about trust Webinar
126. CAD CARE NA To address errors, there are many other models to address errors then blockchain Webinar
127. S L Megha Health Insurance Scheme There are few herbal practitioner which has been recognized as a Dr by authority. can this be allow to register under the HPR in NDHM? Thanking you. Webinar
128. nita Ispirit Health professional associations responsible for imparting CME and CME points should have APIs to update the same for a practitioner upon completion.. this will go a long way on CME compliance during re registrations Webinar
129. nita Ispirit The registries will enhance the trust Webinar
130. Dr. Mayank Agarwal,Agra, India Harvard University I have applied for one Pradhanmantri Jan Aushadhi Kendra and plans to open 3 more at Agra with an intent to include and implement NDHM in its entirety at them, thereby setting also foundations of a Health Information Exchane. What resources do I have from NDHM beside SandBoX. There are some transformational projects running at UK. How can I form a tripartite small Work Group to conceive a small Proof of Concept. Does NDHM endorse any Country Level Health IT Infrastructure ( Like TOpol Revier , Wachter Report on NHS), Radcliffe Report by Haravard on India, ) Webinar
131. Dr. Mayank Agarwal,Agra, India Harvard University US has National Interoperability Plan 2020-2030 and National Health IT Strategic Plan 2020-2025. Can NDHM take and innovate on these two documents.? Webinar
132. Dr. Mayank Agarwal,Agra, India Harvard University HPR Access controls - WHich Standards are being adopted here? Standards Discussions over GNAP vs. OAuth How to authorize access to a health record component The right to delegate authorization as a human right Privacy Issues with OAuth: Vendor Lock-in Unnecessary copies of personal data Censorship Webinar
133. nita Ispirit All practicing doctors have SMC registration no. which has to be displayed Webinar
134. nita Ispirit His presence or absence on HPR and verification status will impact the trust factor Webinar
135. Dr. Mayank Agarwal,Agra, India Harvard University Suggestion - Mission and Vision of NDHM . I asked about the objectives of NDHM as I found NDHM very close to the reasons why Digital Health exists in the frst place. With little carefulness, NDHM can be the SHowcase of Digital Health for SDGs to the world. FROM MEANINGFUL OSE OF EHR to PRECISION MEDICINE Webinar
136. Dr. Mayank Agarwal,Agra, India Harvard University Suggestion - The way i see NDHM is " Health TRANSFORMATION THROUGH USE OF POPULATION HEALTH, DATA ANALYTICS, CARE COORDINATION, VALUE BASED CARE AND PATIENT CENTERED TECHNOLOGIES through use of Health informatics To further Patient safety And Clinical Quality with agility and increased access"." Webinar
137. CAD CARE NA If we’re talking about reach ability then we should make global doctors assessable to NDHM so then ultimately indian people are getting benefited Webinar
138. Dr. Mayank Agarwal,Agra, India Harvard University Pharmacists in this discussion. CAn you please give me some insights and connect with me at 9599943575/ I need some pAin points and GAp Analysis in Indian Pharmacy scene Webinar
139. J singh Jharkhand Medical Council Is it possible to have a Common Medical Register (currently state medical councils and NMC has seperate medical register) so that the data may be on the real time sharing? Also there may be a provision of adding all medical qualification under single registration number as currently we in J&K medical council are giving different registration numbers to a single person for his all medical qualifications. Webinar
140. Dr Ashish Jaiswal NA Comments in attached file View Email
141. Raghavendra Singh NA Comments in attached file View Email
142. Dr SUNDEEP SALVI NA Comments in attached file View Email
143. 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
144. Dr Haleema Yezdani NA Yes having a registry and providing good jobs according to the registry is definitely a good thing Website
145. 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
146. Sivani Peesapati General Electric 1. -The stakeholders section in 3.1 generalizes healthcare professionals and in subsequent section 4, does not talk about radiologists. They should also be considered as key stakeholders and need to be part of HPR database. - Another stakeholder (section 3.1)that has not been explicitly captured are medical equipment manufacturers. They have been broadly placed as part of healthtech. But, the need of equipment manufacturers is different. Equipment manufacturers would be benefited if they have access to all the data about health service managers and radiologists and lab technicians. As key stakeholder, equipment manufacturers would recommend that HPR is focused on ecosystem centric vision and not on patient centric vision(section 4.2 and 4.3). -The benefit for a healthcare equipment manufacturer from the data by seeing the availability of radiologists v/s doctors availability would help in setting up tele medicine, tele ICU setups at places it would work. In a broad way, it will be beneficial for the healthcare equipment manufacturer to identify the demand. 2. 5.6 HPR – HFR Linkage: This is a good step and will have huge benefit for patients and health care equipment and solutions providers too. But, this will have an impact on the privacy of the healthcare professional. With information about him along with his professional place of work also available, the risk of cyber attacks and eventually the impact of information leakage increases manyfold. - This document talks very less about how the privacy of the healthcare professional would be safe guarded and how he will be compensated in case of a leak. Also, the paper does not talk about who would be the person/role that will be held accountable in case of information breach in the registry. We might have to create Data Protection Officers either at state level or for each stakeholder level who can be reached out to in case of breach of data. Also, the paper needs to explicitly mention how much the healthcare professional shall be fined if unfortunate incident of leak of data happens. This will ward of fears and motivate more healthcare professionals to get onto the platform. 3. 5.3 Mode of data entry Another important item that is missing in the paper and would be important for adoption of HPR among healthcare professionals would be the feature of consent to be included while they enter the data. While they self register, it is important that they get a list that talks about where all their ID can be used and if they want to give consent. Bare minimum consent can be made mandatory that is required for patients to get the right treatment There are many healthcare professionals like mid wives and ASHA workers who might not be able to do self registration. So, assisted registrations like what is done for AADHAR should also be setup. 4. 5.4 Data Types Data being collected can all be classified as personal information. Hence, the registry should also include a deidentification functionality. All the entered original data should be deleted after the verification and ID should be associated only with deidentfied data to keep the impact to minimum in case of breach. Website
147. 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 Website
148. 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 Website
149. Dr. Ujjwal Rao Rector Health Recommendations for subsuming "Privileging" of healthcare professionals in the HPR. View Website
150. Dr. Saurabh Bhalla Employee State Insurance Corporation Respected Members of the Team , I am attaching my opinion as a professional, which has been there in the country since 1950's and luckily it was first to come in India in whole of ASIA and SARC nations as well, with association so Gold that even WORLD FEDERATION of OCCUPATIONAL THERAPY (WFOT) was founded because All India Occupational Therapy Association (AIOTA) was one of the founding members. I duly request all the Honorable members to Kindly help make India INDEPENDENT and let's have INTER-DISCIPLINARY work at least at Government Setups. Kind Regards. View Website
151. Nitthin Chandran Medpiper Comments attached in the file View Website
152. Anirudh Rastogi Ikigai Law Dear Madam or Sir, We hope you are keeping safe and healthy in these difficult times. On behalf of Ikigai Law, I have attached our comments on the Consultation Paper on Healthcare Professionals Registry. Please write to us for any further information. Thank you for giving us this opportunity. Regards, Anirudh Rastogi View Website
153. Syed Quasim Ali - Practo Practo Thank you Webinar
154. Dr. KM Annamalai The Indian Association of Physiotherapists Sub: The Indian Association of Physiotherapists representation regarding National Health Authority to organize public webinars for stakeholders to brief on National Digital Health Mission’s Consultation papers - Webinars on consultation papers - Health Facility Registry (HFR) & Healthcare Professionals Registry (HPR) to be held on 6th July & 7th July and extension of last date for consultation papers to 20th July 2021 – Submission - Regarding Respected Sir / Madam, With reference to the notifications called for regarding Healthcare Professionals Registry, by National Health Authority, Govt of India held on 6th& 7th July 2021, we the members of the Physiotherapy community (The Indian Association of Physiotherapists) wish to bring following points to your kind consideration and notice. 1. Definition: as per various State Councils and NCAHCP Act 2021” Physiotherapy is a Modern Medical Science” and “Physiotherapeutic System of Medicine”. This drugless mode of therapy must reach every common public till rural level to benefit those who Need Physiotherapy. 2. As per National Commission for Allied and Health Professions Act 2021, Physiotherapists are allowed to practice independently. Hence in the Health setup “Physiotherapy should be listed as Distinct “Specialty” like Ortho, Neuro, Cardio and Alternate Medicine, etc. 3. As per the study hours prescribed by the Model Curriculum prescribed by Ministry of Health Govt of India and “National Commission for Allied and Health Care professions ACT 2021”, Physiotherapists study 4 ½ Years course period with minimum 3600 hours to 4500 hours which includes 6 months Internship period (CRRI). Hence BPT holders deserve to be given a distinct specialists status on par with Medical, Dental and Alternate Medicine graduates as Health Care Professionals. 4. Moreover a Physiotherapy graduate study the following subjects which are unique and equips only Physiotherapists to decide on “Prescription of Physiotherapy Modalities and Therapeutics as they only study these and it’s their Domain as Specialists study. a) Bio Mechanics which helps in diagnosing Bio Mechanical disorders of Body b) Bio Patho Mechanics c) Assessment of Bio mechanical functioning of joints and abnormal Bio Mechanical changes (Patho Mechinic changes), correction and improvement of functional outcome. d) Kinesiological assessments and Rehabilitation in various functional disorders. e) Physiotherapists study on Human body motions, maintenance of functional activities and corrections and preventions functional and Physical Disorders , can be called as Physical Evaluation and Diagnosis. Hence it’s high time that Physiotherapy field should be considered as specialty and granted expert status in the Medical field. 5. In Annexure -1 Consultation-Paper-on-Health-Facility-Registry – in column under “Field Sub Inputs” in column “Field Sub choice, it is listed as “Physical Medicine Rehabilitation (PMR) / Physiotherapy”, which is incorrect. Physiotherapy is a separate distinct specialty and Physical Medicine and Rehabilitation” should not be listed along with Physiotherapy as it will appear both fields are equated. This will create a misunderstanding of professional. Hence Physiotherapy alone to be listed as separate “Field Sub Choice”. 6. In Annexure -2 Consultation -Paper-on-Health-Facility-Registry, Column 119 “Field Name” it is listed as “Allied Health Professions”. Please note as per the “Allied and Health Care Professions Act 2021” there are two different category. 1) Health Care professionals” 2) Allied health Professionals”. Hence this listing of many Health care Professions including “physiotherapy” under “Allied Health professions” is in incorrect. Hence please create TWO different “Field Name” such as 1) “Health care Professions” and 2) Allied Health Professions” and list the Physiotherapists professions into to Health care Professions. 7. Each Hospital (including Medical College, District, Taluk and Rural health Centres must have Physiotherapists and establish Independent Department to cater needy public without any hurdle and NOT to clubbed with Physical Medicine and Rehabilitation Departments, as Physiotherapy study contents, Diagnosis, planning and execution of Physiotherapeutic System of Medicine is most unique in nature. 8. All Physiotherapy Departments must come under the Dean or District Medical Officer or Joint Director of the Hospital directly like other specialty Departments. 9. Separate Superintendent Physiotherapists or Chief Physiotherapist must be appointed to service and monitor Physiotherapy services of the respective districts. 10. Physiotherapy Departments must get financial grants every year to develop the Physiotherapy services in the respective districts like other specialties. 11. A National and State Physiotherapy separate Registry should be created to list the practicing Physiotherapists in India. 12. Physiotherapist must be listed as consultant like other specialties in the Hospital notices and public notices. We sincerely thank Honorable Prime Minister, Honorable Health Minister and Health Authorities for considering Physiotherapy as Independent Profession and allowing independent practice. We anticipate that our request will be duly considered for next level of growth of Physiotherapy Profession and Physiotherapy services in India. Thanking you in anticipation. Dr.Sanjiv K Jha Dr.K.M.Annamalai President General Secretary The Indian Association of Physiotherapists Website Website
155. Partha Ranjan Das Department of Physiotherapy, Vydehi Hospital, Bangalore Myself a Physiotherapy Doctor/Physiotherapist/Physiotherapy Healthcare Professional. I strongly support The National Health Professionals Registry which is a wonderful thing going to happen in India from health perspective. Keeping Physiotherapy in a exclusive separate category is the best step taken by the NHA, giving Physiotherapist their age old Rights and keeping Physiotherapy domain under only Physiotherapist and excluding all professionals especially PMR and other System of medicine. The Consultation Paper of Physiotherapy should consists of : Physiotherapy Assessment, Prescribing Radiological Investigations, Diagnosis and Treatment includes Electrotherapy, Exercise Therapy , Rehabilitation of locomotor disabilities according to our Specialties. The above content is as per the recent THE NATIONAL COMMISSION FOR ALLIED AND HEALTHCARE PROFESSIONS ACT, 2021 Website
156. Anant Sharma Choithram hospital and research centre indore Occupational therapy is noble profession and need of India in prevention and curing disabilities. Website
157. Ambalam M Chandrasekaran NA Content: There is no scope for registering Yoga & Naturopathy doctors in the NDHM website. Kindly make provision for the same. Currently there are around 50 Yoga & Naturopathy Medical Colleges affiliated to renowned universities like NTR University of Health Sciences, Telangana & Andhra Pradesh, The Tamil Nadu Dr. MGR Medical University, Tamil Nadu, Rajiv Gandhi University of Health Sciences, Karnataka etc., Till date nearly 10000 doctors have been graduated and more than 10000 students are currently pursuing BNYS Medical degree in these universities. Nearly 16 states have state regulatory bodies for Yoga & Naturopathy system of medicine and Central Council for Research in Yoga & Naturopathy governs the regulatory aspects of Yoga & Naturopathy profession under the aegis of National Board for Promotion & Development of Yoga & Naturopathy, Ministry of AYUSH. Hence, we kindly request you to make provision for registering Yoga & Naturopathy doctors in the NDHM platform. Thanks and regards, Website
158. Dr Gurudatta H K Anandamaya Wellness Center I don't understand why BNYS (Bachelors of Naturopathy & Yogic Sciences) Doctors who are qualified from their respective universities and registered in their respective state AYUSH Boards are not considered in Healthcare Professionals Registry? Time and again we are a neglected lot from GoI even after repeated requests and letters sent to AYUSH ministry from the practitioners and association. Even after so much encouragement for Yoga from our beloved PM and across the globe, why this secondary treatment for BNYS professionals. There are more than 50 BNYS colleges across the country affiliated to the respective state medical universities and nearly 10000 Doctors practicing across the country rendering efficient services to the community. Even then, we need to beg for formal central registration? I do not understand this!! Is there a lobby which is working against us within the GoI? The relevant authorities have come out open with their hidden agenda, instead of giving false promises. Or the lobbyists are fearing the rise of Yoga & Naturopathy as a system in the general public and scientific community with several research papers coming out? Kindly request the authorities to take necessary steps and action to include Yoga & Naturopathy Doctors for this registry without any time lapse. Website
159. Rohin Garg Internet Freedom Foundation Analysing the NDHM Health Data Management Policy View Email