Canada Health Infoway
Inforoute Santé du Canada

OAG Recommendations and Infoway Responses

Canada Health Infoway (Infoway) welcomes the eight recommendations made by the Auditor General of Canada in chapter four of her report tabled to the Parliament of Canada on November 3, 2009.

Infoway is committed to implementing all the recommendations made by the Auditor General over the next four months prior to the end of the Corporation’s 2009/10 fiscal year. In its action plans the Corporation has focused on timely, efficient and effective implementation of strategies with due regard for cost.

Setting direction

1. To ensure Parliament and Canadians properly understand Infoway’s goal, the Corporation should further explain in its public reports what is meant by having an electronic health record available to authorized health care professionals.

Infoway’s Response:

We agree with the recommendation and we will make additional efforts to elaborate on the goal of having an electronic health record available to authorized health care providers in our public reporting commencing with our 2009-10 Annual Report and/or the 2010-11 Corporate Business Plan.

Implementation of electronic health records is a complex task, as is reporting on progress. We have made continuous improvements to progress reporting and will continue to enhance our reporting in the future.

Infoway reports on a regular basis jurisdictional progress to making electronic health records available to Canadians. For example, we provide Members of Parliament and Senators with copies of our Annual Report and Corporate Business Plan. We also post these materials on our website to help ensure the broadest possible distribution to Canadians.

Actions^*:

• Assessment and analysis of current reporting on “availability” completed
• Draft wording improvements for inclusion in public reporting underway
• Focus group testing of revised and enhanced wording to elaborate on the concept of availability to be conducted in January 2010
• Implementation of enhanced “availability” goal wording for the 2009/10 Annual Report, 2010/11 Business Plan, the Infoway Website and other external communications to be completed by February 2010
• As required by the Federal Funding Agreement; Business Plan available April 30, 2010
• As required by the Federal Funding Agreement; Annual Report available June 30, 2010

2. Infoway should review and strengthen its management controls over contracting for goods and services to reduce the risk of contract disputes.

Infoway’s Response:

We agree to review and analyze current practices to strengthen management controls. Improvements to management controls related to the timing of contract signatures will be put in place by to the end of the 2009-10 fiscal year.

We do not pay any invoice unless the contract is acceptably executed and the Infoway manager has certified that the product or service has been appropriately delivered by the contractor.

Actions^*:

• Analysis of issues around timing of contract signature process as identified in the OAG sample is completed
• Process work flows and controls concerning contracting signatures reviewed in light of issues identified has been completed
• Development of internal communication and education messages and face to face sessions to raise awareness of risks associated with non-compliance for contract signatures are under development
• A shift in management controls with specific check points by the procurement department for monitoring the signature of contracts an renewals earlier in the workflow chain is underway
• Improved vendor communication and notification for contract acceptance to avoid start date issues will be implemented by mid November 2009
• Issue of advance warning reports on contracts to expire or contracts due for renewal in the next 90 days has been implemented
• A review and assessment of additional improved workflow tools for procurement related documents is underway with analysis and implementation to be completed by March 31, 2010

3. Infoway should review its contracting policy with respect to contract amendments and extensions to ensure fairness, transparency, and disclosure to the Board.

Infoway’s Response:

We agree to review the contracting policy with respect to amendments and extensions and to present the proposed revisions to the Board for approval prior to the fourth quarter of the 2009-10 fiscal year.

Infoway’s Board-approved contracting policy was developed to respond to competitive market conditions and the often unique and rare combination of skill sets required to deliver the Corporation’s mandate. The current policy reflects the necessary balance between market competitiveness, the Corporation’s business requirements and due respect for the expenditure of public funds. We are compliant with the current policy related to the tendering of amendments and extensions and the reporting of those amendments and extensions to the Board of Directors.

Actions^*:

• Contracting policy analysis in light of OAG observations and recommendations complete
• Revised policy developed, recommended to and approved by Infoway’s Board on September 23, 2009
• Infoway staff briefed and policy put in effect on October 7, 2009

Funding electronic health record projects

4. To ensure accountability and transparency, Infoway should better document its analyses of project deliverables to support its decision to release funds.

Infoway’s Response:

We agree that there is scope for improvement to deliverables documentation and the Corporation will address this issue immediately. This will build on Infoway’s documentation process and methodology for the approval of deliverables, including the third-party claims verification process that assesses the adequacy and effectiveness of the policies, controls, and systems in place for the management of Infoway-funded projects.

Actions^*:

• Current documentation analysis and deliverables payment review process completed
• Update of the Corporation’s current documentation software to accommodate new process requirements is in progress
• A pilot of the new process documentation for a selected jurisdiction or region for December 2009
• Staff training on the new process and requirements in parallel with the pilot to be completed by January 2010
• Full implementation of new process February 2010

5. To ensure that standards will be properly implemented in the five core systems of an electronic health record, Infoway should obtain from the provinces and territories the results of conformance testing on systems it will fund, and obtain assurance that non-conformance issues, if any, will be resolved.

Infoway’s Response:

On a go forward basis, for new investment approvals, and with the co-operation of the jurisdictions, we agree to work to obtain the results of conformance testing from the jurisdictions on the five core electronic health record systems we will fund in the future and obtain assurance that non-conformance issues, if any, will be resolved.

We have acknowledged that there will be variations in systems requirements and thus standards requirements within jurisdictions. Jurisdictions have the mandate and authority to ensure conformance and perform user acceptance testing to their specific requirements. They are most familiar with those requirements and are best positioned to ensure they are met. Some differences are valid within a specification and require no action, whereas some are due to different maintenance releases of a standard used by various jurisdictions largely driven by their timeline for implementation. Despite variances in standards conformance, the use of a standard within a jurisdiction will ensure interoperability within that jurisdiction.

Pan-Canadian interoperability can still be achieved and differences in standards can be mitigated by

• ensuring the same standard is used for cross-jurisdictional interoperability, or
• mapping to accommodate differences in the implementation of the standard. We believe that this is not only feasible but also practical and cost effective.

Actions^*:

• Review and assessment of the recommendation is complete
• Conformance assurance criteria where a standard(s) is/are required in the project to be funded is underway
• Update of contracting and legal agreements to include the requirement for standard conformance documentation is underway
• A funding gate will be established and funding to be paid for the confirmation of the sponsor’s conformance or assurance that non-conformance issues will be resolved is underway
• The recommendation will be implemented on a go forward basis starting with the first new core EHR project approval

Reporting on results

6. To ensure Parliament and Canadians have sufficient information about progress achieved, Infoway should report on the extent to which electronic health record systems have been adopted by health care professionals and are compliant with standards.

Infoway’s Response:

We agree with the recommendation, recognizing, however, that solution implementation and availability must be completed before adoption can occur. These major project initiatives often take 24 to 36 months to be fully implemented.

Infoway, in conjunction with the jurisdictions, will endeavour to develop measures on the extent to which EHR systems have been adopted by health care providers. Further, Infoway will work with jurisdictions to develop a standards compliance report.

Actions for reporting on adoption^*:

• The current adoption definition leads to usable systems being deployed and funding payment targets for adoption criteria for projects have been defined
• Systems to track adoption payment progress are in place
• Analysis of how best to report to the public on project adoption payment targets is underway
• First reporting on key adoption investment targets to be incorporated in the Corporation’s 2009/10 Annual Report and enhanced in the 2010/11 Annual Report

Actions for reporting on standards compliance^*:

• Framework and categories for reporting on standards compliance is completed
• Data collection and information to populate the framework is underway
• A process to track and update the framework is under development
• First reporting to be incorporated into the 2009/10 Annual Report, and updated annually thereafter

7. To ensure Parliament and Canadians have sufficient information about progress achieved, Infoway should report on results achieved compared with expected results and explain any difference.

Infoway’s Response:

We agree to report on variances between expected results and achievements related to the electronic health record goal line in our public reporting beginning with the 2009-10 Annual Report.

This will build on the Corporation’s existing reporting on expected results and actual performance in our Annual Report (in the section entitled, Delivering Results: Performance Against Objectives). We provide Members of Parliament (MPs) and Senators with copies of our Annual Report and Corporate Business Plan. Last year, we undertook an initiative (which we plan to repeat annually) to provide MPs and Senators with jurisdictional fact sheets to highlight EHR advancements within their respective region.

Actions^*:

• Building on existing reporting in the Annual Report the Corporation will report on variances between expected results and achievements as relates to progress and variance on the stated EHR goal line beginning with its 2009/10 Annual Report

8. To ensure Parliament and Canadians have sufficient information about progress achieved, Infoway should report on the results achieved for performance targets established for each core system of the electronic health record.

Infoway’s Response:

We agree with the recommendation. The Corporation will need to finalize its work with the jurisdictions on both data availability and data quality, to ensure that additional reporting will be accurate. This will build on the Corporation’s existing reports on the value, benefits, and advancement that electronic health record systems are delivering to Canadians through our proactive media relations efforts, corporate materials, and the Internet, as well as through hundreds of public presentation and speaking engagements.

Actions^*:

• Infoway has defined investment program targets in its Board approved Corporate Business Plans and will use these targets to define the baseline for future reporting
• Development of a reporting framework is complete
• Assessment of data availability and data quality is underway
• Review of data reporting timeframes and confirmation of data updates with the jurisdictions and other data providers is underway
• The processes and systems to facilitate tracking and updates to reports is under development
• First reporting with available data will begin in the 2009/10 Annual Report and will be enhanced and updated in the 2010/11 Annual Report

^*As of December 14, 2009