The National Health Authority (NHA) of the Department of Health and Family Welfare recently published a consultation paper on the Register of Health Institutions (HFR). This registry will be introduced as a singular database for health facilities, as opposed to the current system where data on hospitals, clinics, etc. is scattered across multiple vertical areas of the Ministry of Health. The system is currently in operation on a pilot basis in six Union areas in the country.
Main principles of HFR
- Voluntary opt-in and opt-out
- Institution ID, which ensures that the content is unique and that there is only one entry for each institution
- Entities in the registry manage their information on their own
- Audit trail for changes made in the registry
- Links to existing databases
This consultation paper comes almost a year after the Indian technology lobby group iSPIRT proposed a system of consensual exchange of health information between health care providers (such as hospitals, pathology laboratories and health users (such as doctors) as part of the National Health Stack). The present paper shows many similarities in this regard; For example, the introduction of registers that store “masters of entities – users, organizations or systems”, the sharing of data, and so on. The health facility registry is also mentioned in the recently published draft implementation strategy of the National Digital Health Mission (NDHM). In the draft, the government designates HFR as one of the core blocks of the NDHM.
It is important to note that the system is operational in the 6 UTs in the country. This consultation paper has now been drawn up following responses from those involved in the pilot project raising concerns about the effectiveness of the proposed system. These concerns are –
- Involving the private sector and how they can be effectively involved in the project without compromising the security aspects of data usage
- Current status of the lack of internet connection and penetration in certain parts of the country
- Resistance to stakeholder adoption of technology
The HFR consultation paper is not only a database of health facilities, but also provides an insight into the overarching system that the National Health Authority is proposing to integrate health facilities into the system. We’ll cover the main components proposed under the HFR before going into a little deeper about them later.
- HFR data refers to the consented information or data attributes reported by each healthcare facility.
- Health Facility Verifier refers to a government or private entity that verifies the data attributes entered by the health facilities.
- HFR organization / program refers to entities that issue licenses, certifications, etc. to healthcare facilities
- Open APIs integrated through the National Digital Health Mission (NDHM) sandbox will help entities in the HFR ecosystem interact with the registry.
Minimum identification information required for all
The HFR data relates to the information or data attributes for each healthcare facility. These attributes include management information that can be used to uniquely identify and locate a facility. While institutions have the option to choose whether to provide data such as financial data, a minimum set of data is mandatory. They include –
- Details of the institution’s contact person
- Furnishing details
- Type of service
- Type of ownership and Other
Detailed information that healthcare institutions may refuse to provide in the register includes information on departments and services, medical and civil infrastructure, quality metrics and accreditation, etc.
Health Facility Verifier will have a separate platform
A Health Facility Verifier (HFR) refers to an independent third party legal entity enrolled in the NDHM who is responsible for verifying the data in the HFR. The registration is currently being checked by the UT administration in the pilot project that is being carried out in the six UTs. To become an HFR, the company can –
- State institution
- Partnership under the Limited Liability Partnership Act
- Companies incorporated under the Indian Company Registration Act
- A promise
- A private company registered under the Indian Companies Act
The HFR can enter data, collect evidence, verify the data in the HFR. The verification process can either be carried out using a platform developed by NDHM or the company can build its own alternative platform and integrate it into NDHM using APIs.
“With this alternative, NDHM can build the technology portal as a common building block and then enable other market participants to replicate the platform; Individual organizations eligible to become a health facility verifier and enrolled with NDHM have the freedom to develop an independent data verification platform for health facility verification provided the platform complies with guidelines set by NDHM and is with HFR using NDHM -APIs integrated “, the consultation paper said.
‘HFR organization can verify data for business purposes’
HFR organizational / program units are units involved in activities including, but not limited to, licensing and certification for healthcare facilities, implementation of government health and insurance programs, involvement of hospitals as insurance companies and external administrators, and the active use of the data of a health facility in the above-mentioned activities.
You can a –
- Body recognized by the central or state government
- Body entrusted with the implementation of government health programs or programs.
- Body entrusted with conducting activities related to government health insurance programs or systems.
- Any private or autonomous body that is involved in the issuing of classifications or certifications for healthcare facilities
This particular entity can integrate with the HFR either by using APIs developed by NDHM or by doing an “independent review of the HFR data for its business purpose”. If they choose to do so, the matter must be reported to the HFR via the API, according to the consultation paper.
Information to be provided via Open APIs
The National Digital Health Blueprint plans to make some of the information contained in the registry open source with the consent of the health institutions that will be included. This information is made available through open APIs and NDHM sandboxes where stakeholders can integrate and test their solutions.
The consultation paper lists stakeholders who can integrate into the HFR using open APIs and sandboxes –
● Consumer health / technology organizations
● Development organizations and NGOs
● financial institutions
● Pharmaceutical and medical device industries
● Universities and research institutes
● Industry organizations
How is the data managed in HFR?
All data in the HFR, unless verified by a health facility verifier or an HFR organization / program, is deemed to be “self-declared” by the health facility, the consultation paper states. Once the verification is done and the final data has been submitted to HFR, the status of that particular data field will be updated to “Verified” or a blue check mark will appear next to the field to indicate that the field is verified, the consultation paper said.
Reliable data standards –
- Once created, HFR data cannot be deleted or changed without following proper procedure
- All data in HFR can be ‘supplemented’ with a new version number of the same data with all changes
- All data created and transmitted in HFR must be traceable to the point at which it was created
- All creation, changes and access to data should be logged in a verifiable and reliable manner.
- The facility manager can access / view his own data at any time and control the access of others by sharing his consent with other parties involved in every data exchange
iSPIRT proposed this system a year ago
In 2020, as part of the National Health Stack, iSPIRT touched upon the creation of a registry of health facilities as part of the iSPIRT as “fundamental building blocks that can be built as a SHARED digital infrastructure and used by both the public and private sectors”. The current form of HFR proposed in this consultation paper shares many similarities with the iSPIRT version.
> Registration: The concept of creating an electronic registry system that houses both healthcare providers and healthcare facilities was first proposed by iSPIRT in their ongoing discussion on the National Health Stack. Although most of the discussions iSPIRT has had on the matter, the details of which are available on its website, centered around the registry of health care providers, at one point iSPIRT says, “These registries enable efficient discovery and authentication of doctors and hospitals, and other healthcare providers. “
>insurance: When talking about the benefits of the National Health Stack, iSPIRT emphasized faster processing of insurance claims and easier involvement. This is mentioned in the consultation paper in a section entitled “Incentives for State Insurance Systems”. The consultation paper states that the HFR register will help create “transparency in the integration process” and facilitate the “time-bound” processing of all applications.
Open APIs: The dependency on APIs was discussed extensively in iSPIRT in open-house discussions that were comprehensively covered by MediaNama. Although the area of discussion regarding iSPIRT’s APIs mainly concerned health information providers and health information users, the use of open APIs for the health facility registry raises the question: Was this also suggested by the lobby group?