Feedback on Consultation paper on Unified Health Interface (UHI)

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Feedback on Consultation paper on Unified Health Interface (UHI)

Jayakumar Selvaraj

@Jayakumar

August 25, 2021

Public Policy

300

Background

The National Health Authority (NHA) has released a consultation paper on the Unified Health Interface (UHI), for comments from stakeholders. UHI is an open, interoperable platform which intends to connect all digital health solutions and aims to transform the way digital health services are rendered in India. To provide some reference, UHI is designed to be similar to the UPI (Unified Payments Interface) ecosystem which has emerged for digital payments.

Currently, patients and healthcare providers need to be on the same application to avail and provide digital health services, respectively. However, with UHI, this is all set to change. The open network created by UHI will serve as the digital infrastructure for patients and healthcare providers to engage in the discovery, booking, payment and fulfillment of a variety of digital health services across applications. Over time, the services enabled by the platform will evolve with the market ecosystem.

NASSCOM – DSCI Feedback

NASSCOM and Data Security Council of India (DSCI) had the opportunity to engage with a wide range of stakeholders including technology companies that provide ehealth solutions, startups that operate in the ehealth sector, Hospitals, Cloud Service Providers and Information Technology (IT) companies, on the vision laid out in the paper.

In our feedback submitted to NHA we had shared the views and concerns expressed by the stakeholders. We highlighted six broad concerns on the proposal, which are listed below.

UHI can impact the quality of service provided by End User Applications (EUAs) as they lose control over the Health Service Providers (HSPs). Presently, the EUA have complete control of the list HSPs to listed for a particular service. However, with UHI, they will lose this control, and they will no longer be able to curate the HSPs and list all the responses received from the UHI Gate way. This can impact quality of service offered.

Healthcare industry is innovating around creating lifecycle-based outcomes and is moving towards adopting an integrated approach to help patients manage their health better. However, UHI adopts a transactional approach to doctor-patient interaction, which can potentially reduce the role of an EUA to a mere channel for facilitating a transaction. This approach can work in an industry where services are transactional and are standardised to a significant extent, but in Healthcare, this may not be best approach.

Various stakeholders are of the view that a key aspect of the healthcare value chain would be made a commodity, due to UHI. Such commoditisation can provide an easy plugin for digital players with high market penetration, to gain market share quickly and dominate the eHealth space. These digital companies will have an advantage to become the natural winners, because of their large user base. This, in the long term, can impact the level of competition in the market and enable concentration of market power with few large players.

Today, except for a small minority, most healthcare service providers like hospitals, labs, etc. have not adopted Health Information Systems (HIS) for managing the health/medical records of their patients. Most hospitals still do not use software except for billing purposes and for booking appointments. Most HSPs may not have the technical infrastructure to integrate in the UHI ecosystem and may require significant investments to bride the technology gap. Therefore, government should provide some incentives and support for Technology adoption.

Even among the small minority of HSPs that have adopted a HIS to manage health records of the patients, the systems do follow multitude of standards, different versions of standards and in some cases, even customization of some older standards. Therefore, it is important to recognise that the interoperability of these systems is not guaranteed currently. This is another hurdle to the interoperability envisaged in UHI.

The draft takes a position that the need for multiple gateways will be considered after a certain period. We believe there is the need for multiple UHI gateways to ensure competition between players, which in turn will act as an incentive for innovation. Therefore, NHA should consider playing a proactive role to ensure more than one gateway is available when UHI is implemented. This is necessary to ensure there is no first mover advantage among the players, which can stifle competition to a significant extent.

Apart from the above, we also suggested that there is a need for more discussions and interactions between the government and the industry to evaluate the impact of UHI, given the massive potential of the UHI to alter the market dynamics. NASSCOM and DCSI can organise few focused interactions with various stakeholders to evaluate the possible impact of UHI, discuss the key concerns of the industry and to identify possible mitigative measures.

Our submission to NHA is attached, for you information.

Update

NASSCOM, along with industry members, had a meeting with the officials of NHA to discuss our feedback on the consultation paper. In the interaction, we discussed the above concerns of the industry and made certain suggestions that can address some the key concerns.

We suggested that providing a safe harbour for EUAs, using standard contract to clearly define the responsibilities of the EUA, introducing an assisted model for the users who may not understand technology and incentivising adoption of Electronic Health Records (EHR) by HSPs be considered.

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Jayakumar Selvaraj

Jayakumar