Submission to eHealth Ontario, Regarding Feedback on Ontario’s eHealth Strategy, 2009-2012

CMHA Ontario supports the development of an eHealth Strategy that will improve health care for all Ontarians. We are pleased to see significant investments in eHealth to advance the Strategy toward its goal of achieving a province-wide, comprehensive electronic health record by 2015. (February, 2009)

 The Canadian Mental Health Association, Ontario (CMHA Ontario) welcomes the opportunity to provide feedback to eHealth Ontario regarding the draft eHealth Strategy for 2009-2012.

CMHA Ontario is a non-profit provincial organization committed to improving services and supports for individuals with mental illnesses and their families. We achieve our mission through effective policy analysis and knowledge transfer, contribute to the advancement of healthy public policy and support the implementation of an effective and efficient health system. We charter 32 branches that provide a significant portion of the community mental health services and supports offered across Ontario.

CMHA Ontario supports the development of an eHealth Strategy that will improve health care for all Ontarians. We are pleased to see significant investments in eHealth to advance the Strategy toward its goal of achieving a province-wide, comprehensive electronic health record by 2015. We believe that our organization has much to contribute to the successful realization of that vision, particularly in ways that promote continuity of care between primary care and community-based service providers.

This review responds to two of the questions posed by eHealth Ontario and highlights ways in which CMHA Ontario can contribute to the Strategy’s implementation.

Is the Strategy to achieve Ontario’s eHealth Clinical Priorities on the right track?

The draft Strategy focuses on three clinical priorities: tools to control and manage diabetes more effectively; online management of prescription medications to minimize preventable adverse drug events; and reduced wait times in Ontario emergency departments. All three priorities are relevant to consumers of community mental health services; CMHA Ontario has been actively involved in many aspects of these areas. People living with a serious mental illness are at significantly higher risk of experiencing a wide range of chronic physical conditions, including diabetes. CMHA Ontario has been working in partnership with government and other health agencies to develop a policy framework that recognizes the interdependence of chronic disease management and the needs of individuals with a serious mental illness. Our efforts are currently focused on integrated chronic disease prevention and management for individuals living with a serious mental illness, and specifically for those who require diabetes care. The lessons learned from our investigations may help inform the diabetes management priority of the eHealth Strategy. We would be pleased to contribute our understandings about this issue as the Diabetes Management priority is rolled out.

People with mental illnesses tend to be prescribed multiple medications to manage both psychiatric and chronic physical conditions. Prescription management can have positive impacts on outcomes for individuals living with a serious mental illness. We also welcome the implementation of the Drug Information System to replace the current Drug Profile Viewer, as currently there is a possibility that people whose records are located in the Viewer and who are under the age of 65 will be perceived to be on social assistance as this group represents the majority of Ontario Drug Benefit recipients with the exclusion of seniors. We would be pleased to provide our further analyses of these issues as part of the implementation of the medication management priority.

Mental health consumers have been identified by the Ministry of Health and Long-Term Care as a special concern in terms of the access to and quality of care received in the Emergency Department and through diversion strategies in appropriate community care settings. Waits are often excessive for people with mental illnesses seeking emergency services; cultural and attitudinal issues have also been identified as impacting negatively on services received and discharge to appropriate follow-up care. CMHA Ontario recently provided advice to the Minister of Health and Long-Term Care in partnership with five other provincial mental health and addictions organizations proposing strategies to reduce emergency wait times for individuals with a mental health or addiction problem, and improve patient flow to inpatient and community-based settings. The eHealth strategy provides real opportunities to measure and improve care and system coordination for those with a serious mental illness presenting to the Emergency Room as well as for those being diverted to appropriate crisis management alternatives in the community.

Integrating community mental health and addiction services more closely with primary care has been identified as a top priority by many Local Health Integration Networks. To that end, eHealth initiatives that enhance continuity of care between primary care and community mental health and addictions agencies should be prioritized. Electronic referrals can be a key enabler of the system; much work has already been conducted through the eReferrals and Access Tracking project to understand the information needs of community providers when sending and receiving referrals. One pilot project provided e-referrals from The Scarborough Hospital to our CMHA Toronto Branch, and from the Branch to other community service providers. There are many lessons learned from that project that could further inform the implementation of the Strategy, particularly in its demonstration of successful end-user engagement.

The development of a comprehensive Electronic Health Record will have implications for the way that privacy and consent are implemented. Some community mental health agencies in Ontario are already working with common electronic client records shared among several health information custodians, and/or are participating in e-health initiatives that introduce new ways of collecting and sharing personal health information electronically, such as the Community Mental Health Common Assessment Project. While all Ontarians have an interest in protecting their personal health information, people with mental illness are particularly vulnerable to stigma and discrimination if adequate safeguards and consent mechanisms are not implemented. We are pleased that the draft eHealth strategy endorses the principle of “privacy by design.”

We would further encourage that eHealth Ontario consider opportunities for community sector organizations to conduct Privacy Impact Assessments (PIAs) as they plan to implement eHealth programs such as those described above. PIAs can build trust in Electronic Health Records by reducing the risk of privacy breaches, however PIAs can be resource intensive and require IT expertise that may be unavailable to smaller agencies. Some CMHA branches have conducted PIAs in the development of their shared electronic records and could serve as resources in considering the expansion of the clinical priorities to community settings.

In what ways do you see yourself contributing to the success of this Strategy?

CMHA Ontario is actively engaged in providing advice and guidance to several provincial eHealth projects within the continuing care sector. As a member of the Continuing Care eHealth Council, we have worked closely with our provincial counterparts in long-term care, community support services, and the Community Care Access Centres, to provide leadership in the development of eHealth standards, common assessment tools, management information systems, and a successful e-referrals and access tracking project. In addition, many of our branches have developed coordinated access solutions, bed registries, and other electronic tools. We have also been a strong advocate for the Mental Health Service Information Ontario, the provincial information and referral system for all community mental services funded by the Ministry of Health and Long-Term Care and coordinated by ConnexOntario.

With the new eHealth strategy, we see an opportunity to continue providing advice at the provincial level, through such bodies as the LHIN eHealth Leads Council and the Strategic Advisory Council. At the project level, CMHA Ontario is well positioned to facilitate consultation with the community mental health sector and to identify individuals from the field to participate on steering committees and expert panels for key projects.

Our knowledge transfer efforts ensure the mental health sector is well informed of health policy and health system developments including the progress of eHealth initiatives. We can boost the Strategy’s chances of success by engaging the field through communications and knowledge exchange activities to raise awareness, educate, and inspire. With direct connections through our branches to the local LHIN planning tables, we can also contribute to informed planning and decision-making on local eHealth projects.

Conclusions

We are very supportive of the efforts being undertaken by eHealth Ontario and applaud your aggressive but necessary timelines for moving forward. We believe we have considerable skills and expertise to bring to your efforts and are ready to collaborate in any way that can advance your work.