Stakeholders Comments on UHI Consultation paper


S. No. Name Organisation Remarks/Feedback Attachments (if any) Comment Source
1 Prince Gupta Consumer Unity & Trust Society (CUTS International) Comments in the attached file View Email
2 Dr. Ajay Nair Swasth Comments in the attached file View Email
3 Aapti Institute Aapti Institute Comments in the attached file View Email
4 Aashita Dagar Coforge Comments in the attached file View Email
5 Raman Jit Singh Chima Access Now Comments in the attached file View Email
6 Amol Pandit NA Comments in the attached file View Email
7 Qasim Ali Practo Comments in the attached file View Email
8 Bhanupreet Saini Internet and Mobile Association of India Comments in the attached file View Email
9 Prasad Kompalli mfine (NovoCura Tech Health Services) Comments in the attached file View Email
10 S Jayakumar NASSCOM Comments in the attached file View Email
11 Santosh Shevade NA Comments in the attached file View Email
12 Shreya Narayan NA Comments in the attached file View Email
13 Nandini Chami IT for Change Comments in the attached file View Email
14 Arjun Natarajan NA Comments in the attached file View Email
15 Dr. Varun Gupta 1mg Comments in the attached file View Email
16 Praveen Kumar Mittal FICCI Comments in the attached file View Email
17 Satish Kannan Medibuddy Comments in the attached file View Email
18 Gokila Ganesan NA Comments in the attached file View Email
19 Dr. Isani Mishra General Electric Comments in the attached file View Email
20 Mamta Abichandani infineon Comments in the attached file View Email
21 Anonymous Attendee NA Hope the recording will be shared. Webinar
22 Dr. Naveen 3M EHR System: Will NHA mandate a uniform EHR system (allowing state based modification) for whole Indian health system Webinar
23 Dr. Naveen 3M Health Professionals: Is there a plan to create a separate workforce like Health Information Management Professionals (HIMPs) for apt data collection Webinar
24 NHM ODISHA National Health Mission And PPT Also Webinar
25 Dr. Naveen 3M Natural Language Processing (NLP): As a part of Digital India and National Digital health Mission, Is Govt. contemplating the usage of Natural Language Processing (NLP) technologies like Converting voice to digitized records and converting hand-written to well coded data Webinar
26 Dr. Naveen 3M Diagnosis Related Groups (DRGs): As efficient resource utilization is one of main future steps in PMJAY, Are any thought given to the Diagnosis Related Groups (DRGs) based reimbursement system for the future Webinar
27 Dr. Naveen 3M Longitudinal health data (LHD) & Population health management (PHM): What are strategies, the government is going to encompass for ensuring the development & management of Longitudinal health data (LHD) for better Population health management Webinar
28 Pr Secy , IT WB Government of West Bengal Pls share presentation with state governments. Webinar
29 Pr Secy , IT WB Government of West Bengal Hope the recording will be shared. Webinar
30 Pr Secy , IT WB Government of West Bengal Hope the recording will be shared. Webinar
31 Kousik Rajendran NA Is UPI going to use FHIR for its request/responses? Webinar
32 Prashanth Adiyodi NA I would like to propose MPI and would like to ask of that is being implemented ? Webinar
33 Haritha RK NA Is it economically feasible to have a data controller at each health facility? Or is there an alternative to protect the data security. Are there any laws to be proposed in the coming future for data security regulation Webinar
34 Prashanth Adiyodi NA By MPI I mean Master Patient Index Webinar
35 DMC NA What are the role of State Medical Council's under UHI besides that we need to verify the registered medical practitioner under NDHM Webinar
36 Raunaq pradhan Bajaj Finserv 1. Will the appointments be handled by doc/ doc mapped to a provider? The payment will accordingly need to be handled by the Software providers to map to their relevant payment IDs
2. Any thoughts on handling the slots for appointment since different service providers might have different formats on how they define slots for booking appointments?
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37 Haritha RK NA Objectives - Linking all the previous tests and medications undergone by the patient for tailored diagnosis and treatment planning Webinar
38 Vijay Anand Ismavel NA Will data transfer be descriptive and use generic formats or should they follow standards like ICD-10, LOINC, SNOMED, DICOM etc.? It is suggested that simpler formats will be easier for remote rural hospitals and poor patients to access the service. Webinar
39 Anonymous Attendee NA How can its works in rural area and hilly area where internet faciliticis are not availabe. Accordiing to my personal knowlege in India more than 50% populations are not used internet services. Webinar
40 Dr Abhinav Suri National Health Authority Who will function as a Regulatory/ Monitoring Body with guidelines for fulfillment of services post payment Webinar
41 Niraj Garg Siemens Healthineers Is this workflow of booking services, price -discovery, service-discovery etc.. applicable for emergency/acute-care situations also ? Webinar
42 Raunaq pradhan Bajaj Finserv 3. Should the consent be implicit while sharing or receiving records for appointment and if I have linked my appointment to a provider from the PHR app (QR Code journey).
The practical scenario being if I go to XYZ hospital. they have all the health records - which they can share with Dr A, or Dr B who are a part of the hospital XYZ. While sharing records across Dr A or Dr B, is a consent needed again? or is it implicit?
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43 Himank Meenakshi NA logo overlapping youtube presentation Webinar
44 Shreekanth Joshi Persistent Systens pleas share more details on policies to be complied with by EUA and HSP applications, the paper is vague on this aspect Webinar
45 revathy Philips Can you pls explain a bit more on the HIE building block in UHI Ecosystem? Is that a Patient Data registry or application registry? Will a transperent interface for different types of data look-up be provided via UHI (say assuming it to be a all-purpose gateway) or a Technology Service provider need to directly talk to NDHM building blocks? Webinar
46 Shreekanth Joshi Persistent Systens can the gateway redirect to the HSP application for detailed service fulfillment? Webinar
47 Kumar Vineet Special Sec I.T. & E. UP NA IT infrastructure and technical manpower to roll out and run, that is imperative for the state to uphold may please be suggested. Webinar
48 Dr Pramod Jacob NA Can some idea of some principles of the Governance of the Open Health Network be handled ? Even broad based ideas would help Webinar
49 Anonymous Attendee NA Pls let us know where does Health Service Aggregator applications like Practo will fall in EUA & HSP ? or Under TSP’s ? Webinar
50 Kumar Vineet Special Sec I.T. & E. UP NA it is also suggested to roll out small videos that can be easily shared over social media to first stakeholders like doctors and other health infra staff to acclimatise them with the concept Webinar
51 Niraj Garg Siemens Healthineers Topics like HSPs ratings etc..are the ' bells and whistles'that should be considered in the future deployment/versions- UHI in its initial phase needs to basic requirements first. Webinar
52 Dr Abhinav Suri National Health Authority Ratings system for Doctors and Hospitals should ideally have No subjectivity involved but should only have Objective elements of rating Webinar
53 Sourabh Jain NA what will be the legal implications ? like consumers court ? Webinar
54 Ramdev K NA This is Ramdev Krishnan of Tata communication, excellent idea to implement UHI approach. Which is inline in our earlier shared approach for Telemedicine Gateway which was published and being elected as T1.
However, i found this approach is to much of sub ideas involved. billing, pricing, control, dr info, upi is discussed. so for me if i get an opportunity to discuss to those who drafted the architecture will help me to give detailed feedback. otherwise my first comments of this is idea is, it is good idea but will it lead to success might be a focus i am thinking on. I might be wrong but not clear for me at this moment. lots of questions raises.
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55 Romit Choudhury NA Hi - This is Rom from Softbrik and we are working with the EU Commission with our clinical partner (AyurVaid Hospitals in India) to set up a Covid Risk Assessment Sandbox. We are establishing Medical GDPR in multiple language for end patients across Europe. Will there be similar Data Privacy standards implemented for UHI flow? Thanks & Regards Webinar
56 Alpesh Patel NA is that any provision to interface our HMIs with EHR system?? Webinar
57 Deepak Haridas NA Is there a plan to integrate Evidence Based Medicine to the platform for standardising care across the country? Webinar
58 Vijay Anand Ismavel NA To confirm ID of the patient, it is suggested that biometric login be used (finger print on smartphone) as this will be convenient to illiterate patients. Webinar
59 OmRx OmRxDoc Going back to the telemedicine use case explained earlier, how will a Doctor using a HSP software X, chat or video call a patient using an EUA Y? For e.g., how can a Doctor using say the Practo app have a video call with a patient using the Mfine or Lybrate app? Webinar
60 revathy Philips The concept of fair service Discovery is good and much needed for adoption. From a Technology service Provider standpoint is it possible to share more information on all the capabilities (initial version) available for discovery (via Specifications or automated discovery ). This is slightly unclear on what all hooks need to be provided by Tech service provider to UHI ecosystem. If we intend to share this post specifications review then pls feel free to skip this question. Webinar
61 Dr. Sunil Sarathy NA Sir, If a hospital in a rural area, which has no IT systems in place can be onboarded so that the public has visibility of the facility or it is mandatory for them to have a IT system running in place to be on boarded Webinar
62 Haritha RK NA Can we use same UPI as Aadhar instead of a separate health ID Webinar
63 sri vidhya bhavani NA With related to Continuity of care One suggestion There are numerous type of non-communicable disease which are not popular. If we can enable patient community group it will help patients to interact with similar type of patients. This will help to improve the quality of life Webinar
64 Dr. Sunil Sarathy NA Since Many States are talking about PHR based services, can NDHM generate the UHID's of the all citizen Beneficiaries and share it to all the citizens through their registered mobile and also to the state so that the states can plan their services with beneficiaries as a denominator Webinar
65 Anonymous Attendee NA Will UHI share anonymized data with technology developers technology enhancements? Webinar
66 Rucha Mahale AP Government If database will not be managed centrally. will it be at state data centers. how will they be merged? Webinar
67 Neha (Product Manager, Piramal Swasthya) Piramal Swasthya Thanks for the session Team!
1) How do we ensure that the ecosystem is adopted by patients who do not want to disclose their identity? E.g. PLHIVs
2) In the context of mental health and geriatric care, how does UHI plan to include services and adoption for pyschotherapy and palliative care? The professional registries will be a building block for this but how do we ensure services are provided/handle grievances in such cases?
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68 Abhishek Singh Nagarro Will there be any seperate RFP for the selection of MSP who will responsible for managing the UHI and its operations? If yes, by when RFP will be floated? Will it be an open tender or only empaneled vendors would be eligible to participate? Webinar
69 Prashanth Adiyodi NA Hi, Patient registry is not what I meant ?, are we creating a system to identify patients with their demographic details over an ecosystem , this will be needed for historical data Webinar
70 Aparna Jatayu Health In some Covid-19 vaccination certificates, there is a UHID that is newly getting populated. Is that the Unique Health ID as envisioned in NDHM? OR is that completely diferent? Since vaccinations are going to be given to most of the adult population, this might be a good chance to provide unique health ID. Webinar
71 Nikhil Yadala NA Can 3rd party companies get access to the anonymized data for research like biomarker discovery, like identifing markers for onset of disease etc. In this case, does NDHM own the IP or the 3rd party company or both? Webinar
72 Alpesh Patel NA i think EHR only useful if atleast more than 50% of indian population involve within 1 year, so i suggest it to make it more simplyfy and try to get already exisiting data with UHID, HMIS,Medical counsil, PMJAY software etc Webinar
73 anand Ruby Hall from where, end user can get a set of all Open API Webinar
74 sri vidhya bhavani NA With related to Price Discovery
This is a good service. But how can we validate. For example., A scenario: A patient goes to a hospital suspecting for Covid with mild symptoms. The hospital admits, saying the patients needs to be in observation as she is diabetic and comes from a village where there is no immediate hospital nearby. And bills around 1 lakh after 4 days. So she claimed for insurance. But insurance gets declined saying her condition doesn’t meet AIIMS guidelines. So how will a common man handle this situation through UHI?
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75 Dr Pramod Jacob NA Altogether - the thought and plans for UHI is very encouraging, even the draft is good in principles - sure it will improve and get even better after the feedback process. We would like to thank the decision makers and stakeholders for firstly this forward thinking plan and we appreciate the feedback being taken - best wishes for this very important digital health platform and sure the community will step forward to support and advocate for this very important platform - Jai Hind Webinar
76 NHM ODISHA National Health Mission How UHI will help a common man Webinar
77 sunita nadhamuni Dell Technologies Good presentation. Can you please comment on the relevance and application of UHI for the Government health sector, for eg. services provided under Health and Wellness Centers? Webinar
78 gokila NA How do we submit access request for sandbox environment? Is that open to all or what’s the criteria to fetch access? Webinar
79 AR NA Suggestion- Regarding continuum of care- consent management and carry over of data between HSPs for one patient or instance. Eg: if a Telemedicine app allows the Dr prescribe a drug or lab test and pushes it to the proffered or tie-up pharmacy then consent and data control will need to be managed. Not sure if this is already addressed Webinar
80 sri vidhya bhavani NA Is there a way where researchers who have worked on Health Information Systems can join this community?
I am a researcher from IIT MAdras Department of Management Studies worked with HMIS Tamilnadu and HIS with private hospitals.,
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81 Sushant Sonar India Health Action Trust I have submitted the form for the access for sandbox environment but havent received any revert on the same, what is the timeframe for receiving the access Webinar
82 anushka Medianama Hi, how will NDHM control any third party sharing of data from HSP’s? Will the DEPA be taken into the NDHM framework as well? Webinar
83 revathy Philips For enabling longitutinal Patient record , the data can reside where it is as you mentionde Praveen Sir. However towards analytics or being data made available to National Health Analytics Stack how do we intend to share the data for future purposes - like say COVID-19 outbreak progression? Webinar
84 sri vidhya bhavani NA Data duplication can be managed with AAdhaar id Webinar
85 Saurabh Gupta NA Will the transfer of historical data record be done by the government or be given to a technology services provider? Webinar
86 sri vidhya bhavani NA Plug and play can help Webinar
87 Vishwas Virani NA Please have maximum payment options including cash payment at hospital/clinic. Webinar
88 Sudha M J NA what are the ethical issues you are anticipating and what is the process planned to handle the same ?! Webinar
89 sri vidhya bhavani NA How will UHI help to improve drug monitoring ?
For example long term non-communicable diseases try out new medicines to improve quality of life. Some medicines get tested in US and comes to India after 2 years. By now there comes another medicine in US. How can we know that doctors provide us the latest medicine? Will UHI help patients to interact with the drug manufacturers to monitor the disease management ?
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90 Anonymous Attendee NA Will the UHI also connect hospitals with insurance companies? For example, will UHI make the dataavailable to insurers for health risk analysis, or treatment detailsfor claims processing? Webinar
91 Sekhar SeMT NA Please share the MOM Webinar
92 Dr. Leila Jacob NA For UHI - please explain the EUA collection of payments for tele consultation - are we keeping this even when ther services is free at point of service Webinar
93 Angshuman ThoughtWorks View Email
94 Ishani Mishra NA Comments in attached file View Email
95 Rahul Handa MarSha Health xpansive but doesnt seem to cover 1) How / where / why will the doctor enter data ? 2) How will the tech company get paid and by whom ? 3) How will the government push the uptake across private hospitals View Website
96 Satya Venu Gopal Malyala Appiarise IT solutions private limited India home to 135 + crore people, that speak 23 vernaculars further divided into thousands of dialects, has ~ 65% of population under the age of 35 years, with an average life expectancy of ~ 70 years. India is the largest democracy in the world, a place like no other on Mother Earth. We are a vast heterogenous mixture, have our very own rich, diverse, unique cultures and social fabric. Yet, India ranks poorly on many indices such as Human development Index, Global Hunger Index, GDP – per capita to mention a few, notwithstanding the concerted, relentless, holistic efforts of successive governments & government agencies. The COVID-19 pandemic has ravaged the country, tested the collective psyche & resilience of India, but has also exposed the gaps in our public health infrastructure, like never before. That is, our lack of health infrastructure, healthcare personnel to serve the nation has been highlighted in a number of publishes some of which are policy documents put forth by MoHFW NHA at this precarious situation has taken a very bold step to turn an adversity into an opportunity and embarked on the roadmap set forth by the National Digital Health Blueprint (NDHB). While some important building blocks have been built over the last one year, their development has been haphazard leading to post correction. UHID is one prime example of this. In this response, we provide accurate, unbiased opinions on why & how a standards based NDHE needs to be setup for UHI and the pitfalls of making it a centralized solution for all the services. We believe : • UHI should serve as a single source of truth for accessing information from the registries • Service discovery, booking, fulfilment should be left to the EUAs & HSPs with regulatory oversight from NHA • Grievance redressal should be maintained by NHA • Avoid rating & reputation for now We offer in detail explanation in the relevant sectionsIndia home to 135 + crore people, that speak 23 vernaculars further divided into thousands of dialects, has ~ 65% of population under the age of 35 years, with an average life expectancy of ~ 70 years. India is the largest democracy in the world, a place like no other on Mother Earth. We are a vast heterogenous mixture, have our very own rich, diverse, unique cultures and social fabric. Yet, India ranks poorly on many indices such as Human development Index, Global Hunger Index, GDP – per capita to mention a few, notwithstanding the concerted, relentless, holistic efforts of successive governments & government agencies. The COVID-19 pandemic has ravaged the country, tested the collective psyche & resilience of India, but has also exposed the gaps in our public health infrastructure, like never before. That is, our lack of health infrastructure, healthcare personnel to serve the nation has been highlighted in a number of publishes some of which are policy documents put forth by MoHFW NHA at this precarious situation has taken a very bold step to turn an adversity into an opportunity and embarked on the roadmap set forth by the National Digital Health Blueprint (NDHB). While some important building blocks have been built over the last one year, their development has been haphazard leading to post correction. UHID is one prime example of this. In this response, we provide accurate, unbiased opinions on why & how a standards based NDHE needs to be setup for UHI and the pitfalls of making it a centralized solution for all the services. We believe : • UHI should serve as a single source of truth for accessing information from the registries • Service discovery, booking, fulfilment should be left to the EUAs & HSPs with regulatory oversight from NHA • Grievance redressal should be maintained by NHA • Avoid rating & reputation for now We offer in detail explanation in the relevant sections Thank you for the opportunity to express our point of view View Website
97 Devraj Goulikar Tata Consultancy Services Comments attached in file View Website
98 Abhijeet Landge Philips Healthcare Dear Sir / Madam, We at Philips Healthcare appreciate the focus on the Unified Health Interface (UHI) building block within the National Digital Health Ecosystem (NDHE). Having closely reviewed the UHI Consultation Paper we have drafted our comments for your perusal. At Philips, given our focus on healthcare informatics we have proven expertise in multiple areas, both technology-wise (Cloud, Interoperabililty Solutions, EMR and Hospital Information Systems) and faculties of medicine (e.g.: Cardiology, Oncology, Neurology etc.). We would be glad to have a workshop to jointly discuss and exchange our respective experiences in this field. Regards, Abhijeet View Website
99 Kumar Satyam Karkinos Healthcare Private Limited To Sri. Vikram Pagaria, Joint Director (Coordination), National Health Authority 9th Floor, Tower - 1 Jeevan Bharati Building, Connaught Place New Delhi - 110001 https://www.nha.gov.in/ Dear Sir, This has reference to the invitation for comments vide the Consultation Paper on Unified Health Interface (reference: Consultation Paper 03/ 2021). Our team of clinicians and experts have reviewed the consultation paper and based on our deliberations have responded on each of the questions raised by the NHA via this consultation paper. We believe the framework discussed in this paper will enable an ecosystem that will benefit the patient and the patient family in case of some really debilitating diseases. Getting the right information at the right time and closest to the citizen will help in achieving an affordable and accessible goals of a healthcare ecosystem. We at Karkinos Healthcare look forward to provide our perspectives of a patient journey we are enabling for oncology patients in the healthcare ecosystem, we will continue to share our learnings with the community and via the open consultation process enabled by the NHA. Kind Regards Kumar Satyam, Deputy Chief Product Officer, Karkinos Healthcare Private Limited View Website
100 Bishakha Bhattacharya Amazon Internet Services Pvt. Ltd We will seek an opportunity to interact with the team and discuss the ideas and recommendations in the enclosed feedback. View Website
101 Bharat Gera NA Sharing my individual response to UHI View Website
102 Sanjeeth K G Ubiqare Health This suggestion is from the doctor perspective, on how does the doctor come to know or discover the patient's health records, Suggestion is to provide UHI Query to retrieve metadata of events/encounters in chronological order, and based on this metadata he could request permission to view these records to the patient Website
103 Anirudh Rastogi Ikigai Law Respected sir, We trust your team and your safe and well. Thank you for the opportunity to provide our comments to the consultation paper on the unified health interface. We have uploaded our comments for your consideration, and are happy to meet with you to discuss them in greater detail. With thanks and regards Anirudh Rastogi (Founding and managing partner, Ikigai Law) View Website
104 Swarnendu Chowdhury IHX Private Limited View Website
105 Priyoma Majumdar (Head of Legal) Threpsi Solutions Private Limited Attaching herewith the Company's feedback on the UHI Consultation Paper. View Website
106 Dr Preeti Goyal IHO We will seek an opportunity to interact with the team and discuss the ideas and recommendations in the enclosed feedback. View Website
107 Geetanjali Bisht Pacta View Website
108 Ramesh Raghavan Coforge View Website
109 Manasije Mishra DocOnline Health India Pvt Ltd Dear Sirs, We welcome the implementation of the NDHM vision. This will, over time, create a very positive impact on the health care ecosystem of the country. We would also like to congratulate you on the systematic way in which you are implementing the project, involving all stakeholders, and asking for feedback at every step. Our comment are on the attached pdf file. They also follow: Chapter 2 2.2. BENEFITS & RISKS a) An important & urgent benefit is the discovery of the availability of medicines, beds and other resources are a critical requirement today and is an important benefit. b) Enabling payments is another important benefit. The risk is that patients may be reluctant to pay in advance, and health care facilities may insist on advance payments. This will be especially true from stand along doctors or small brands. The NDHM can mitigate the risk and become a trusted third party that collects the fee from the patient in advance and only sends it to the health care provider once the service is delivered. c) An important benefit is the opportunity to quickly establish data standards so that we start to see coding of diagnosis, drugs, treatment procedures, diagnostic tests. While the use of images and scans is ok as a first step, there is a significant risk that this will remain the practice for a long time. To mitigate this risk, there should be defined sunset clause for different types of information. Machine readable data is critical as it will help in the individual treatment by identifying issues as well providing information to the doctors about the changes over time. Just providing a summary of previous diagnosis, current medication prescribed by different doctors and a list of medical procedures will have significant benefits as this information is very easy to overlook when dealing with scans and images. There are also massive benefits of aggregated, anonymised data to the community. Chapter 3 Q 3. Are there any other primary or secondary stakeholders that should be considered while building the interface? If yes, please outline their role in the UHI ecosystem. We should include: a) Primary Heath care clinics and providers. (Including digital providers) - HSPs b) Insurance companies - payers c) Subscription based health care services – payers, HSP d) Wellness companies - HSPs Q 4. Please comment if there are other objectives which must be included in section 3.4. While the paper does mention data & digital information, this really needs to be called out as a important objective of NDHM. We would recommend the following additional objectives: Establish data standards for coding of diagnosis (for primary care & also secondary & tertiary care), drugs, treatment procedures, diagnostic tests. While the use of images and scans may be allowed in the initial phase, there should be defined sunset clause for different types of information. Machine readable data is critical as it will help in the individual treatment by identifying issues as well providing information to the doctors about the changes over time. Just providing a one or two-page summary of previous diagnosis, current medication prescribed by different doctors and a list of medical procedures will have significant benefits as this information is very easy to overlook when dealing with scans and images. There are also massive benefits of aggregated, anonymised data to the community. This can help with: i) Establishing a Digital prescription format with diagnosis codes, biometric data, and standard drug codes. This digital prescription can flow to pharmacy systems. This will reduce the changes of the wrong drugs being dispensed. Also this will allow for the development of systems that provide alerts about drug interactions based on patient history. The Dubai Health Authority has established a e prescription system that could provide some learnings. ii) Diagnostic report in a standard, machine-readable format is a crucial objective missing in the document. It will help to track changes over time as well allow for the development of systems that can generate a simple presentation for doctors as well as insights and alerts. Currently doctors rarely have the time to look as a large volumes of scanned or paper records. iii) Exchange of information between hospitals and insurance companies. iv) Hospital can quickly access emergency medical information of the patient who met with an accident or other critical condition. v) The design of government and non-government programmes to address the needs in specific geographies or population. vi) Generation of community level clinical insights that would be critical inputs for drug development, and improvements in treatment protocols etc. Another objective that should be considered is the possibility and facility to use of Hindi and other local languages in the ecosystem. Q.5. UHI will support a range of digital health services and is expected to evolve with time. What digital health services should the initial version of UHI focus on? We recommend the following phases: STEP 1: Availability of hospital beds, oxygen beds, ICU beds, ambulances, diagnostics, and other critical care facilities. STEP 2: Establish data standards for coding of diagnosis (for primary care & also secondary & tertiary care), drugs, treatment procedures, diagnostic tests. While the use of images and scans may be allowed in the initial phase, there should be defined sunset clause for different types of information. Machine readable data is critical for sharing information and will help in the individual treatment by identifying issues as well providing information to the doctors about the changes over time. The following phasing may be considered, based on the complexity: Phase 1: Blood test & radiology reports Phase 2: Primary care diagnosis codes Phase 3: Drugs – coding the pharmacopeia Phase 4: Implement digital prescription eco system Phase 5: Coding of diagnosis and treatment procedures in secondary & tertiary care facilities STEP 3: Personal Health Record – storage and sharing STEP 4: Doctor & Facility discovery & booking and payment system. Chapter 4 Q.6. Have all incentives / disincentives for various stakeholders to participate been covered in chapter 4? If not, please provide the list and mention the role and description of the stakeholder. Payers like health insurance, healthcare aggregators, wellness companies, healthcare providers play a vital role in making healthcare affordable. Payers manage to get attractive pricing for the healthcare services, which are 30-40% lower than walk-in rates as payers drive huge footfall for both OPD and IPD treatments. Q.7. For the disincentives mentioned in chapter 4 and as an answer to Question 1 of chapter 4, please provide possible mitigating measures that may be taken to minimize the impact of said disincentives. Include Insurance companies, healthcare aggregators, wellness companies, and healthcare providers as payers. Including the payers in the system will only help reduce out-of-pocket expenses for both OPD and IPD treatment – this is currently around 60% of the overall healthcare expenditure. Chapter 5 Q.8. In the proposed discovery model in section 5.1.3.1 EUAs are expected to present all responses returned by the Gateway to the user and allow the user to choose the HSP. Should any alternate models be allowed? If yes, provide details. 1. EUA & HSP combination: The paper already allows the same entity to play the role of a EUA and a HSP. This is an important use case as this will cover many hospitals, clinics and telemedicine companies. In case a company is both a EUA & a HSP, it should be permitted to first offer in-house medical facilities including their own doctors, labs. The customer should also have the option of viewing and using the larger ecosystem via the Gateway. Insurance companies, healthcare aggregators, wellness companies, and healthcare providers may also function as EUAs. Such players should be allowed to publish a curated list of providers for both OPD & IPD. For example, a list of hospitals supporting cash less claims. Similarly centres of excellence for specific procedures which may have fixed packages negotiated with the insurance company or aggregator. When an EUA is providing preference to a set of HSP, including itself, this must be clearly communicated to the user. 2. Distance criteria for digital HSPs: The gateway should also consider that digital companies like telemedicine providers are location agnostic and can be accessed from anywhere – including the patient’s home or office. Thus, if the search result is using distance as a criteria, suitable provisions should be made for the display of these digital services. 3. Patient Ratings: The exclusive use of patient ratings may result in sub optimum results. A doctor should provide good customer service, but he should not be in a popularity contest. This may result in un-predictable and clinically sub optimal results and the exclusive use of patient ratings should be reconsidered. Q.10. Are there any other areas that must be supported by the Gateway for service fulfilment in section 5.1.3.3? If yes, provide details. We need consider the data flow back from the HSP. What action of the HSP will be considered for service completion? For example: i) Releasing a digital prescription back to the Gateway to close a OPD consultation ii) Releasing diagnostic reports back to the Gateway to close a health check-up iii) Delivery of medicines for a pharmacy iv) Discharge summary for the fulfilment of IPD services The feedback loop is critical. All the records received by the Gateway can automatically be stored in the patient health records. Ideally the feedback loop should quickly move to structured data and not scans so that digital, machine-readable records can be maintained and used for data presentation & analysis. Q.11. Post-fulfilment, as described in section 5.1.3.5, covers ratings and grievances. Are there any other areas that must be supported by the Gateway for post service fulfilment in section 5.1.3.5? If yes, provide details. Getting a valid prescription, report, or discharge summary in the last six months should be used as criteria to allow a user to rate the healthcare service provider. A health care provider should have an opportunity to connect with the patient and clarify/resolve the grievance. If there is no response from the patient to solve the case within 15-20days, it cannot be considered a grievance. There should be a provision for the patient to change his rating once the issue is resolved. Thank you for giving us an opportunity to provide the feedback. We would be delighted to support NDHM efforts and get involved in the development of India’s health care eco system. Yours sincerely, Manasije Mishra Managing Director Manasije.Mishra@DocOnline.com View Website
110 Neerja Bhatia Confederation of Indian Industry Dear Mr Pagaria, May I please refer to feedback requested from Industry on Consultation Paper on Unified Health Interface published on 23rd July 2021. Towards this, as advised, CII had uploaded consolidated Industry comments and recommendations within the stated deadline of 23rd August, but since we find that our inputs are not reflecting on the portal, we are sending the consolidated inputs via this email as well please. Grateful, if these can kindly be considered and accepted as well please. We sincerely regret if there may have been any inadvertent delay from our side Please do let us know of any further support that we may provide Thank you and regards Neerja ************* Neerja Bhatia (Ms) Executive Director Confederation of Indian Industry (CII) View Email
111 Dr. Nikhilesh Chandra Vardhman Mahavir Medical College & Safdarjung Hospital New Delhi Comments in the attached file View Email