MOH seeks public feedback on proposed framework to share health information among healthcare providers

SINGAPORE: The Ministry of Health (MOH) is seeking public feedback on a proposed framework to share health information among healthcare providers.

The public consultation on the Health Information Bill (HIB) will run from Monday (Dec 11) to Jan 11, 2024, MOH said in a press release on Monday.

The Bill's three main objectives are to ensure health information is kept updated, accurate and accessible; simplify the health data sharing framework to facilitate flow of information between healthcare providers and social care services; and set in place cybersecurity and data security safeguards which providers have to comply with.

The Bill will be tabled in parliament in the first half of 2024, said MOH.

The ministry said that only key health information such as diagnosis, medications, allergies or laboratory reports will be contributed to the National Electronic Health Record (NEHR) as part of the Bill.

This will allow providers access to patients’ summary medical records for better care. 

But providers are only allowed access to relevant information required for them to provide care to patients, said MOH.

It also stated that sensitive health information - those that could lead to social stigma or discrimination - can only be accessed by medical practitioners, selected nurses and pharmacists in public institutions, "based on their role in the care delivery of the patient".

There will be additional requirements that will be imposed on sensitive health information under the Bill.

"These include administrative access controls, such as a double log-in function within NEHR, and mandatory incident reporting requirements should any breach of access occur.

"Any unjustified use or access by unauthorised personnel will be subject to penalties," said MOH.

The Bill will also explicitly disallow data to be used to assess one’s suitability for employment or whether one can qualify to be an insurance policyholder or claimant.

This will ensure that a patient's medical history cannot be used to discriminate against the employability or insurability of the patient, said MOH.

The need for the Bill comes as Singapore's population ages, said MOH in its press release.

The ministry said it expects healthcare needs to become more complex with more Singaporeans having chronic conditions, needing to visit various healthcare institutions and relying on multiple healthcare providers for care.

The health information generated from each visit is currently held by the providers in separate paper or electronic record systems, it said.

The sharing of key health information is beneficial to patients as it removes the need for repetitive laboratory or radiological tests, and for patients to repeat their medical history to various healthcare providers.

"More importantly, by having access to a common set of their patients’ key health information, healthcare providers will be able to make better clinical decisions for the benefit of their patients," MOH said.

The ministry mentioned this as a reason why NEHR was established in 2011. The NEHR is currently used by all public healthcare institutions, while participation from private institutions is voluntary.

As of October 2023, about 15 per cent of private institutions participated in this.

"In Singapore, having developed the NEHR, MOH is proposing to introduce the HIB, which will make it mandatory for all licensed healthcare providers to contribute data to the NEHR.

"This will enable patients and providers to continue benefitting from having access to an up-to-date, accurate and complete centralised national repository of key health information whenever care is provided," it added.

ACCESS RESTRICTIONS OPTION

The Bill will provide individuals the option to place access restrictions on the sharing of their key health information in NEHR.

"This restriction means that no one will be allowed to access the individual’s information within the NEHR, including the individual’s own attending doctor," said MOH.

MOH warned that with the restrictions, an individual "may experience more inefficient care delivery".

This may lead to greater inconveniences, such as having to repeat laboratory or radiological investigations, and "potentially even compromise their safety and welfare, as critical information, such as the individual’s allergic reactions to medications, will no longer be made known to healthcare professionals".

However, this restriction will be overridden in the event of a medical emergency, MOH said.

An example would be when an individual must be medically assessed to be at risk of immediate and significant harm unless medical intervention is given, and is unable to provide consent such as when they are in a coma.

CYBERSECURITY AND DATA SECURITY SAFEGUARDS

With the increase in the contribution, access and sharing of health information across the ecosystem, there is an increasing risk of cyber-attacks and consequences of potential data losses, said MOH.

Therefore, healthcare providers contributing to or accessing NEHR, or care providers participating in data sharing use cases enabled under the Bill will have to meet a "robust unified set of cybersecurity and data security requirements" to protect both electronic and non-electronic health information.

This includes reporting cybersecurity incidents and data breaches such as unauthorised NEHR access that meet the prescribed thresholds to MOH.

These safeguards are necessary in view of the interconnected roles that healthcare and care providers play in the healthcare ecosystem, it added.