Health Identifiers and Information
The implementation of a health identifier will greatly add to patient safety and administrative efficiency. It is also a crucial building block for Money Follows The Patient and Universal Heath Insurance, both cornerstones of the Government Reform Agenda
A provision for health identifiers was included in the Health Information Bill and heads of a Health information Bill were approved by Government in 2009.
More recently, in the context of a commitment given to the Troika in June to publish legislation to give a statutory basis to health identifiers, it became clear that it would not be possible to have all the provisions of that Bill ready in time to meet the Troika commitment; hence, it was necessary to fast track the identifier elements into a separate focussed Bill: namely, the Health Identifiers Bill. The formal drafting of this Health Identifiers Bill was approved by Government on 30 October 2013 and it was published at the end of 2013.
It provides the legal basis for Individual Health Identifiers for health service users and unique identifiers for health service providers. The identifiers will be used across the health service, both public and private.
First and foremost, Individual Health Identifiers are about patient safety and ensuring that the right information is associated with the right individual at the point of care. Individual Health Identifiers will also help in managing our health service more efficiently and will be a building block for health reform initiatives including Money Follows the Patient.
A National Individual Health Identifier Register will be established containing the Identifier and other identifying particulars relating to the individual. These are set out in the Bill. There are two key privacy points here. The first is that an Individual Health Identifier or IHI will be a number which in itself will contain no personal data whatsoever. The second is that no clinical information whatsoever may be contained in the IHI Register.
Access to the National IHI Register will be restricted to health service providers and other entities under the Bill. The Bill provides that measures must be put in place to help ensure that the National IHI Register is accessed only for relevant purposes and by people who are permitted to access it. There are offences and penalties set out in the Bill on inappropriate access.
Health service providers – health professionals, organisations and some employees – will also have a unique identifier. Again, providers will have to use their identifier on their patient records and in relevant communications. This will clearly identify the person and organisation involved at each stage of care. There will be a National Register of Health Services Providers Identifiers containing the identifier, name, business address and other relevant details. The Health Services Provider Register will be publicly accessible.
Assigning identifiers and establishing and maintaining the related registers are functions of the Minister for Health under the Bill. However, for operational reasons, the Bill allows for the possible delegation of these functions to the Health Service Executive (HSE).
We were advised by a Health Identifiers Working Group representing all major stakeholders – D/Health, D/Public Expenditure and Reform, D/Social Protection, HIQA and HSE. The Department also consulted with the Data Protection Commissioner.
The Individual Health Identifier will rely heavily and be closely linked to the Public Service Identity dataset and the SAFE* Public Service Card infrastructure operated by the Department of Social Protection. In this way, the Individual Health Identifier will leverage the significant investment to date and the ongoing work by the Department of Social Protection (DSP).
*Standard Authentication Framework Environment designed to assign a level of certainty to the information held about an individual– e.g. information about a client is only assigned SAFE Level 2 after a face-to-face interview were the client is required to produce documentary, including photographic, evidence of identity
It is not intended to replicate the DSP data collection and verification process, except for a small fraction of cases where DSP does not have information about the individuals concerned (e.g. tourists or temporary residents who are not normally issued with PPS Numbers). This approach will ensure maximum leveraging of the public service dataset (operated by DSP) while enabling the health sector to operate a sectoral identifier. In many respects, the health service will operate from a carbon copy of the public service identity dataset and this will significantly reduce the cost of the initiative.
Health service providers will be required to identify patients and clients who present for service by requesting their Individual Health Identifier or, failing that, identifying particulars (such as name, date of birth etc.) which will enable them to search the register of Individual Health Identifiers. The Bill provides that health service providers must associate the Individual Health Identifier with records they create. However, a health service provider cannot refuse a service solely because an individual cannot, or refuses to, provide his or her Individual Health Identifier.
The proposed system will have features which will reassure the public about the use of health data
- the individual health identifier may not be used in any other sector of the economy or government unless its use relates to a health service e.g. psychological assessments carried out for the education sector
- no clinical information will be held in the Individual Health Identifier Register
- the Bill contains offences and penalties for misuse of the Individual Health Identifier and access to the Individual Health Identifier Register is controlled and limited with supporting criminal sanctions.
Organisational and Professional Identifiers
In line with HIQA recommendations, the Bill includes provisions for the establishment of identifiers for organisations providing health services as well as identifiers for professionals and other staff. These identifiers will strengthen patient safety, privacy, wider regulation and facilitate more robust accountability and audit.
The Bill compels health professional regulatory bodies, such as the Medical Council and Nursing and Midwifery Board of Ireland, to provide information to the Minister on registered professionals. It is intended to re-use the number assigned by these regulatory bodies in the Register of Professionals provided for in the Bill.
Operation of the Registers
The Bill provided that the Minister may delegate the main operational functions of the identifier registers to the HSE by Government order. It is envisaged that the HSE /PCRS (Primary Care Reimbursement Service) will operate the Individual Health identifier Register on behalf of the Minister. PCRS already has considerable expertise and systems in place which can be readily tailored for this purpose.
Health Information Bill
We are also working on a Health Information Bill intended to address a range of matters that will facilitate enhanced information management processes relevant to a modern health system. Those matters will include provisions for: a more streamlined ethics approval process for health research not already governed by statutory regulation and EU Law; data matching programmes and health information resources (for example, patient registries); and improving patient safety including through reporting of patient safety incidents and by promoting a culture of open disclosure to patients.