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National Digital Health Blueprint – Continuum of Care

National Digital Health Blueprint – Continuum of Care

India’s 1.3 billion people seek health care from a labyrinth of public and private healthcare providers. To this date, a large portion of the interactions continues on hand-written records, or is not captured at all. As a country with different and difficult terrains, alike, delivery of healthcare with the employment of ICT solutions is preferable and exists. The need for recognition, regulation, and evaluation of this ecosystem is imperative.

Recently, the Ministry of Health and Family Welfare (MoHFW) on July 15, 2019, released the National Digital Health Blueprint (Blueprint), putting it in the public domain inviting comments/ views. The Blueprint talks about creating a national digital health ecosystem and stresses on creation and management of core health data and infrastructure required for seamless exchange.

OBJECTIVES, PRINCIPLES AND BLOCKS

The Blueprint identifies the objectives for the healthcare sector in alignment with the vision of the National Health Policy of 2017, and the Sustainable Development Goals1 pertaining to healthcare. The primary objective continues to be establishment of infrastructure which will foster seamless exchange; and the provision of a federated architecture underpinned by personal health records (PHR).

The Blueprint also lays down a broad set of principles, categorized on the basis of domain and technology perspectives, separately. The first set includes universal health coverage, awareness and empowerment, inclusivity and most importantly, privacy and security by design. The technological perspective revolves around interoperability, open standards, open APIs and above all a minimalistic approach.

The Blueprint has identified 23 building blocks (dynamic list), and a layered approach has been provided for conceptualizing and effective implementation of the Blueprint. In India, where there has been a lack of social awareness and consciousness with respect to the amount of data we generate, and the vulnerabilities that exist, the Blueprint acknowledges this fallacy and makes an attempt to plug the gaps.

The Blueprint begins with identifying the forerunners in the healthcare sectors, and distinguishes between the care providers, care professionals, payer and other stakeholders. The idea is to ensure that every building block of the care delivery system is mapped to an owner, by delineating between the business owner and the technology owner. While a business owner will be responsible for the purposes of defining the rules and policies to manage and effect the building blocks; a technology owner would be responsible for the technical implementation and efficacy.

Several directories are to be established in the first phase of the Blueprint, coinciding with the identified building blocks spread across the layered network.

STANDARDS AND REGULATIONS

It is necessary to understand that this ecosystem will be premised on the data that is being provided by the patient; this digitization leads to creation of large databases and leaves behind larger footprints. While ICT allows for contributing accessibility, affordability, these enablers also expose the patient to certain vulnerabilities which are not sufficiently gauged by the patients to whom such data pertains to.

The Blueprint has a chapter dedicated to discussing standards and regulations to ensure privacy and security is built into the ecosystem, by specific design. Standards have been identified basis global usage and acceptance, within the chapter. The focus is not just on the consumption of the data and the consent required from the patient for the purposes of processing; but it also looks at standards which are essential to the cause of interoperability and interaction between several building blocks in the suggested federated structure.

Notably, The Blueprint also notes the lack of cohesive, comprehensive directives and laws focusing on the further standards which are essential to be adopted as core and minimal standards.

About Author

Bagmishika Puhan

Bagmisikha Puhan is an Associate Partner at TMT Law Practice. She graduated in 2014, and specializes in Technology Law, advising clients in the ITeS, media, healthcare and pharmaceuticals, space sectors on regulatory, policy, compliance and transactions. A member of the Telemedicine Society of India, Bagmisikha also conducts capacity-building and training programmes. Bagmisikha has worked in-house as part of the Global Data Privacy Team of an Indian MNC and worked extensively in matters pertaining to the data privacy and data protection laws of several jurisdictions.