Key sections of the Health Identifiers Act 2014 (the “Act”) were brought into force recently. The Act provides for the creation of an individual health identifier (“IHI”), which will uniquely identify each person using health or social care services in Ireland. The introduction of IHIs is intended to improve accuracy in identifying patients’ records and to allow them to be shared safely and seamlessly between public and private health service providers. IHIs are widely regarded as essential to the implementation of eHealth systems, such as electronic health records and ePrescribing.
Health service providers will also be given unique identifiers and the Act provides for national registers of IHIs and health services provider identifiers, which are to be established and maintained by a special business unit of the Health Service Executive (the “HSE”).
The sections of the Act which have been commenced to date generally relate to the assignment of IHIs to individuals and the establishment of the associated national register, offences in relation to unauthorised use of IHIs and various enabling provisions, such as sections dealing with investigations by the Minister for Health (the “Minister”), data exchange agreements and the Minister’s powers.
Following the commencement of these provisions of the Act, the Health Information and Quality Authority (“HIQA”) (the body charged with setting and monitoring compliance with standards for health information), published the Information Governance and Management Standards for the Health Identifiers Operator in Ireland (the “Standards”) on 5 August 2015.
The Standards consist of basic requirements to support the introduction of IHIs and guidance for the HSE to establish and manage the National Register of Individual Health Identifiers and the National Register of Health Services Provider Identifiers. The HSE is currently undertaking a privacy impact assessment to investigate the likely effect of the implementation of the National Register of IHIs. Following its publication, it is the HSE’s intention to begin trialling use of IHIs on a pilot basis in certain clinical information systems (the Epilepsy Electronic Patient Record, a multi-GP General Practice and the Electronic Medical Record within a hospice) by the end of 2015.