Most of the discussion around India’s public health infrastructure in the past year has been centred on fighting Covid-19. But amidst this big challenge, India has taken an important step towards better delivery of healthcare by committing itself to building its digital highways through the National Digital Health Mission (NDHM).
If NDHM works, the familiar scenes of hospital waiting rooms with patients carrying binders of their medical records for the doctor’s reference could soon be history. NDHM’s digital infrastructure is envisioned to enable patients to move seamlessly from one healthcare provider to another. It hopes to create and link distributed databases of patient health to ease access for doctors and hospitals while providing add-on services.
Consider a migrant worker from Bihar with a chronic ailment, working as a daily wage labourer in Delhi—he is unlikely to have preserved and carried any of his past medical reports from his hometown. NDHM would allow him to get treatment at a facility in Delhi without going through long registration processes and re-tests, and if eligible, in a cashless manner under the PM-JAY scheme. In time, as the ecosystem develops, he would also be able to avail additional services built on top of the NDHM platform, such as telemedicine, additional insurance products, and even AI-powered diagnostics.
NDHM is being envisaged as an open digital ecosystem (ODE)—a platform that breaks down data silos, enables information sharing with the patients’ consent and enables service innovation to deliver better healthcare to every Indian. While many pieces of the core technology architecture of NDHM are being built, and the network of the hospitals and health-tech providers on the platform is growing, we believe that adoption of NDHM at population scale hinges on getting two ‘non-tech’ elements right: protecting and empowering consumers and building a community of innovators.
NDHM adopts the concept of informed consent, which is welcome. Participation is voluntary; the digital identity and records of patients are shared only after they provide informed consent for a specific purpose and a specific time period.
However, as we know, most people do not understand the nuances of ‘consent’. Privacy policies are long, full of jargon, and often in English. Even the most educated amongst us struggle to comprehend them and share personal data on various apps without fully understanding the consequences. The challenge is aggravated in emergencies when patients are under pressure to quickly sign off on consent notices. So, relying on consent alone is inadequate. Just as food safety certifications and energy ratings help guide our everyday decisions, NDHM can explore ‘privacy ratings’ of various services and apps on the platform to help bridge the information gap between services providers and patients. Similarly, encouraging service providers to leverage the ‘three Vs’—voice, vernacular, and video—to explain consent can make it more understandable to ordinary citizens. NDHM can also consider testing different approaches to consent—messages, tools, nudges—as it rolls out services in the field, such as in the UTs this year.
Beyond consent, NDHM should ensure that the platform and the applications on it adopt best in class ‘privacy by design’ standards, and there is access to time-bound and effective recourse if citizens face any data breaches or harms. Ultimately, the ‘burden of proof’ on privacy should rest with providers rather than citizens, ie, businesses using citizen data should act as fiduciaries of user data, act in their best interest, and be liable if they don’t do so.
The success of ODE depends to a large extent on its adoption by a large network of innovators, who build consumer-centric services on the platform. NDHM has taken a key early step in this direction by setting up a ‘sandbox’. This is essentially a tech framework that allows start-ups and other innovators to test their service products in a controlled environment under a regulator’s supervision before full-scale roll-out. Sandboxes are a win-win: for innovators, they help iron out issues in integrating with a large platform before large scale roll-out. For the facilitator/regulator, the feedback from these early adopters helps improve platform design and develop the right rules of engagement. Currently, the NDHM sandbox is engaging with over 300 entities who are testing innovative ways to, for example, process digital insurance claims, create digital health lockers and connect patients with relevant doctors.
Innovators can also be encouraged through approaches like hackathons, and by showcasing the potential of NDHM through ‘reference apps’, much like the role BHIM played to demonstrate how UPI can transform digital payments. NDHM could also create special campaigns to bring on board innovators who are developing use cases for low-income and underserved communities. Here, NDHM can take inspiration from the RBI sandbox, which has created special cohorts of innovators focused on themes relevant to low-income customers, such as offline retail payments and MSME lending.
NDHM holds huge promise to transform India’s healthcare system, especially for India’s most underserved. Focusing on getting these non-tech layers right will play a key role in helping NDHM deliver on this promise.
This article was originally published in Financial Express on 11th March 2021, and can be accessed here.