The Press Release from PIB has called for public comments on the proposed National Heath Stack. (NHS)
NHS is the proposed scheme by NITI Aayog that envisages maintenance of a centralized health record for all citizens of the country to facilitate better management of the health care. This would be assisting in the implementation of the ambitious “Modi Care” or “Ayushman Bharath” scheme which is planning to cover 5 lakh to 10 crore poor families under a health insurance program.
Obviously there will be privacy issues, data protection issues and Fraud management issues inherent in such a program and its implementation would be watched keenly by the community of experts.
The scheme envisages besides creating a master registry of health data of citizens, a federated personal health records (PHR) framework, a National Health Analytics Platform and other components such as Digital Health IDs, Health Data Dictionaries and Supply Chain Management for Drugs, Payment Gateways etc.
Along with DISHA2018, this document will bring revolutionary changes in the way Health Care and Health Care Insurance is likely to be handled in the coming days.
What would be interesting for Data Protection professionals would be to study the proposed “Data Empowerment and Protection Architecture (DEPA) which would interact with the ID systems like Aadhaar etc.
Apart from the Privacy Considerations, Data Protection Requirements, the possibility of “Frauds” has also been envisioned and some thoughts have been given in this direction.
We have the experience of HIPAA and Obama Care in US and hopefully the lessons learnt by the US authorities in administering those programs would come in handy in India when Modi Care is being planned and implemented.
The Political opponents and the supporting sections of the society will raise many questions and perhaps try to ensure the defeat of the program. But people who are interested in national welfare should welcome this massive project and provide assistance to the Government in implementing it successfully.
If we look at the Aadhaar scenario, there has been a competitive criticism by the professionals in the Privacy and Data Protection industry basically led by the political considerations.
Now NHS scheme could be a “Digital Health Aadhaar” scheme having wide ramifications.
I hope that the opposition that surfaced for Aadhaar does not resurface in respect of the NHS and Modi Care program.
I therefore urge all the Data Protection Professionals who were in the forefront of criticising the Aadhaar and even went to the extent of submitting their own objections to the Supreme Court, collaborated with foreign agencies to find loopholes in the Aadhaar system, to take a deep look at the proposed consultation paper and record their views today instead of coming up with their objections later.
Send your comments if any by 1st August 2018 to firstname.lastname@example.org
[Also refer to www.disha2018.in for information on the proposed Digital Information Security for Health Care Act and the EHR guidelines.]