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Individual Healthcare Identifiers – IHI

In Practices we should only perform IHI lookups for patients as part of providing healthcare to them. Above all, this means that we should not do a bulk look up for all patients in our database.

Also the authority to lookup IHIs does NOT apply if the patient is attending for employment reasons or for insurance reasons. In other words, if a patient attends the clinic solely for the purposes of a pre-employment medical, their IHI should not be accessed or verified.

The blocking of lookup of IHIs is the only legal safeguard against insurance companies or employers accessing MyHealth record. This seems a little bizarre to me, because administrative staff are forbidden to access the MyHealth Record. Presumably doctors who work for insurance companies can, as long as they don’t do IHI lookup or verification. Do you trust your administrative staff to do IHI lookups?

In addition, the intention of the MyHealth record system was always to provide secondary usage of the data.

Legislation

Below is a copy of the relevant parts of the legislation. https://www.legislation.gov.au/Details/C2017C00239
(HEALTH IDENTIFIERS ACT 2010)

Section 14 (1).4

An ‘identified healthcare provider’ can ‘collect from the service operator’ the ‘healthcare identifier of a healthcare recipient’ only when ‘the collection is for the purpose of communicating or managing health information, as part of providing healthcare to the healthcare recipient‘.

Section 14 (2)
This section does not authorise the collection, use or disclosure of the healthcare identifier of a healthcare recipient for the purpose of communicating or managing health information as part of:
(a) underwriting a contract of insurance that covers the healthcare recipient; or
(b) determining whether to enter into a contract of insurance that covers the healthcare recipient (whether alone or as a member of a class); or
(c) determining whether a contract of insurance covers the healthcare recipient in relation to a particular event; or
(d) employing the healthcare recipient.