NASSCOM's Feedback on the Consultation Paper on Operationalising the Unified Health interface in India

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NASSCOM's Feedback on the Consultation Paper on Operationalising the Unified Health interface in India

Sudipto

@Sudipto

January 14, 2023

Public Policy

342

On January 13, 2023 NASSCOM submitted its feedback (copy attached) on the Consultation Paper released by the National Health Authority (NHA) on operationalising the Unified Health interface (UHI) in India that outlined the market rules that will govern the UHI Network.

The Consultation Paper focused on the guidelines that will govern the way search & discovery takes place in a fair and transparent manner. It also includes issues like payment & settlement processes, rules around cancellation & rescheduling and grievance redressal mechanism.

Our main recommendations are as follows:

Mandate an oversight mechanism like periodic audit of Network Participants (NPs) to check that the protocols under the Network Policy are being followed.
Mandate NPs to provide language options other than English to end-users so they can understand the search results.
Mandate the need for obtaining consent of the end-user in the event of rescheduling due to the unavailability of Health Service Provider (HSP), or no-show followed by an option to consult a different HSP (like a doctor).
Clear demarcation of responsibilities between the NPs and the nature of grievances that can be redressed under the grievance redress mechanism of the UHI network should be conspicuously stated on the website of the End User Application (EUA) in English and/or any other language which end-users can easily understand.
Measures should be taken to ensure competition is not impacted and there is no concentration of market power in the UHI network with few large players.
Government should incentivise adoption of electronic health records because most HSPs may not have the technical infrastructure to integrate in the UHI ecosystem and require significant investments to bridge the technology gap. Wide adoption of Health Information System of a reasonable quality is a prerequisite for the success of UHI.
There is need for multiple UHI gateways to ensure competition between players, which in turn will act as an incentive for innovation.

Please see the attachment for our detailed submission and recommendations.

For more details, please write to Sudipto Banerjee at: sudipto@nasscom.in and Garima Prakash at garima@nasscom.in.

UHI NHA National Health Authority

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Sudipto