Accessibility of Healthcare

ANED 2014 Task 4 - Accessibility of Healthcare Country: Ireland Author(s): Charlotte May-Simera The Academic Network of European Disability experts (ANED) was established by the European Commission in 2008 to provide scientific support and advice for its disability policy Unit. In particular, the activities of the Network will support the future development of the EU Disability Action Plan and practical implementation of the United Nations Convention on the Rights of Disabled People.   This country report has been prepared as input for the synthesis report on Access of healthcare in European Countries. Accessibility of Medical records which Patients are Entitled to Access Obligations and Standards Mandatory/Binding Accessibility Requirements applicable to Medical Health Records Access to medical records in Ireland is covered by the Data Protection Acts 1988 and 2003 and the Freedom of Information (FOI) Acts 1997 and 2003. Section 6(1) of the Freedom of Information Act 1997 outlines that every person has a right to access any record held by a public body, which includes medical records. Section 6(2)(b) outlines that it shall be the duty of a public body to give reasonable assistance to a person who is seeking a record under this Act if the person has a disability, so as to facilitate the exercise by the person of his or her rights under this Act. In general, the FOI legislation applies only to public bodies. As a result, it applies to the records held by GPs for their medical card patients, but it does not apply to records that they hold in respect of their private patients. The FOI Acts also apply to all public and voluntary hospitals; to services for people with intellectual disability; and to services for people with physical disability. An individual is entitled to see a copy of any records medical practitioners keep that relate to him or her on computer or on paper. This right of access is also outlined in Section 4 of the Data Protection Acts and is subject to a limited exemption (Section 5 of the Data Protection Acts) that declares that individuals do not have a right to see information relating to them where allowing access would be likely to damage the physical, mental or emotional well-being of the individual. Technical Accessibility Standards or Guidance relating to Medical/Health Records The HSE’s (Health Service Executive) Code of Practice for Healthcare Records Management was issued in 2007. It replaced the Policy for Health Boards on Record Retention Periods issued in 1999. The 2007 Code sets out detailed standards for the creation, maintenance and storage of health records. These standards are meant to apply to all healthcare facilities. It sets out the recommended retention periods for health records in publicly funded hospitals. Citizens Information Bureau, 35(10) Relate (2008). There are specific rules in relation to access to personal health data. They provide that access to your personal health information may be refused if it would be likely to cause serious harm to your physical or mental health. If the person controlling access is a health professional, then that person may make the decision; if not, then he/she may consult with a health professional. If the data controller does not comply with the legislation, you may complain to the Data Protection Commissioner and may seek compensation in the courts Data Protection Act Section 10(9). The Medical Protection Society of Ireland has produced a Guide for practitioners and medial experts on Medical Records in Ireland. Medical Protection Society, ‘ Medical Records in Ireland,’ (2012). As regards standards on Health Information security management, the Guide refers to the National Standards Authority of Ireland for comprehensive guidance on all aspects of records management and security: ISO15489:2001 (Information and Documentation – Records Management), the ISO standard ISO27799 on Health Informatics: Information Security Management in Health this standard is based on ISO/IEC27002 – Code of Practice for Information Security Management. These can be purchased at www.standards.ie The Medical Protection Society explain that requests for access to the records of a patient who is mentally incapacitated must be decided on a case-by-case basis, bearing in mind that the interests of the patient are paramount. Practitioners are permitted to withhold access to part or all of the record if there is a real possibility that viewing it would result in serious damage to the patient’s physical, mental or emotional wellbeing. This would be a rare circumstance explain the Medical Protection Society, and such a decision should be based on sound clinical judgment, reasons for withholding the information should be clearly documented. The patient has the right to ask the Data Protection Commissioner to investigate the matter. Ibid., 28. In accordance with the Health Act 2007, The Health Information and Quality Authority (HIQA) Under the Health Act 2007, the Health Information and Quality Authority (HIQA) has a statutory remit to develop standards, assess value for money and cost-effectiveness, evaluate information and make recommendations about deficiencies in health information. The importance of information to the Irish health system has been highlighted by a number of government and external organisations. The Department of Health has produced a number of key national strategy documents since 2001 highlighting the importance and need for quality health information to improve the safety and quality of patient care. is responsible for setting standards in the health sector. In May 2013, it produced a set of 8 Guiding Principles for National Health and Social Care data Collections in Ireland. Principle 5 on Use of Information declares that information produced by the national health and social care data collection is accessible to data users in line with legislation and disseminated to optimize its benefit. In the Guidelines HIQA outline that appropriate governance arrangements will ensure that robust operational procedures and processes are in place, clearly communicated, and easy to access for everyone involved in the data collection. Health Information and Quality Authority, ‘Guiding Principles for National Health and Social Care Data Collections’, (2013), at 13. In April 2011 HIQA had produced a report in which it considered standards in accessing health information by identifying themes for standards for National Health Information Sources. Health Information And Quality Authority, ‘Identification of Themes for Standards for National Health Information Sources in Ireland’, (2011). HIQA argue for the introduction of standards and claim that, the end users of health information will benefit from greater accessibility to relevant information in a timely manner, knowing that the integrity and security of the data is assured. Furthermore, standards will enable the quality and quantity of healthcare research to increase by improving the consistency, accessibility and quality of information by ensuring that the information accessed from national HI sources is more usable and useful. Ultimately healthcare users will in the long term be the key beneficiaries, receiving better safer care and an improved return on their investment as taxpayers. Ibid., at 14. In the report HIQA also comment that, once developed the standards must also take into account usability of data, referring to the extent to which data can be accessed and understood. Health Information and And Quality Authority, ‘Identification of Themes for Standards for National Health Information Sources in Ireland’, (2011). Guidance on ethics is provided by the Medical Council, which is the regulatory body for doctors, in its Guide to Ethical Conduct and Behaviour. These state that keeping accurate records is in the interest of both doctors and patients. Records “should be retained for an adequate period (this may be for periods in excess of 21 years)”. The guidelines also stress the importance of storing records in a manner that ensures confidentiality and security. These guidelines cover all doctors and are available at www.medicalcouncil.ie As regards the records of General practitioners the doctors’ representative bodies have issued a non-binding guide to Managing and Protecting the Privacy of Personal Health Information in Irish General Practice. Litigation or Other Publicly Documented Complaints about Inaccessible Medical Records No evidence found in Irish Case law, equality authority or tribunal or with the ombudsman (Supreme Court decisions or High Court decisions). The Information Commissioner however, (The Office of the Information Commissioner reviews decisions made by public bodies in relation to Freedom of Information requests) has referred to, on a number of occasions, problems with GP medical records. The contract between GPs and the Health Service Executive (HSE) includes a general requirement to keep ‘adequate clinical records’ but does not set any standards about the type of medical records to be maintained or the length of time for which they should be retained. There are arrangements for dealing with records when a GP ceases to practice for whatever reason but the Information Commissioner says these are not very specific and they appear to lack a proper implementation mechanism. Office of the Information Commissioner, ‘Health Services and the law’, available at: <https://www.oic.gov.ie/en/news/speeches-articles/2012-speeches-articles/health-services-and-the-law-–-some-reflections.html> (accessed 11 June 214). Accessibility of Medical Records in Practice Extent of Accessibility The Medical Council in its Guide to Professional Conduct and Ethics (2009) states that patients are entitled to receive a copy of their own medical records, provided it does not put their health (or the health, safety or privacy of others) at risk. This right of access is provided for by law. Medical Council, ‘Professional Conduct and Ethics (2009). The Citizens Information Board of Ireland reports of developments in social services, policy and legislation and declares that: … apart from the data protection legislation which sets out general rules about the creation and retention of records, there is no specific legislation on the maintenance, control and retention of medical records. There are EU rules in relation to records of clinical trials (the records must be retained for 20 years). Citizens Information Bureau, 35(10) Relate (2008). Good Practice Examples None identified. This could be partly explained by the general lack of guidance or standards on accessibility (Health information Bill not yet passed- see below at 1.3.), as well as the gradual, fragmented implementation of information systems in the public health system in practice. Ongoing Developments Commitments to Improvement During 2006, the NDA and the HSE agreed to develop a Guidance Document aimed at improving the accessibility of all health services in Ireland. It is envisaged that the project will be completed in 2007. The guidelines will address the six key dimensions of accessibility in health services: Disability awareness training, Customer relations, Information provision, Infrastructure and buildings, Equipment and devices, Procurement. National Disability Authority: http://www.nda.ie/cntmgmtnew.nsf/0/4D4264F175BE4030802573930046CB0E/$File/annrep2006_07.htm. No comprehensive document has been produced yet, or it could be found albeit, the NDA has produced guidelines on some issues individually, such as procurement. See: http://www.nda.ie/website/nda/cntmgmtnew.nsf/0/BAB19FE32B5A2AE8802570C100345C48?OpenDocument. The development of national standards for health information governance (IG) is at the forefront of the Irish health information agenda, explain HIQA. The objective of the current Health Service Reform Programme is to deliver better patient care and safety. This means using information – in manual and electronic form- more effectively to improve healthcare outcomes and an individual’s control over his or her personal health information. Moreover, the introduction of a Health Information Bill has been proposed. This Bill would deal with the collection, use, sharing, storage, disclosure and transfer of personal health information, as well as the rights of individuals to control and access their health information. The Department of Health conducted a public consultation exercise on a proposed Health Information Bill in 2008. The Department prepared a thematic Synopsis document setting out the main points raised by stakeholders. The report is available here: http://www.dohc.ie/issues/hib/synopsis.pdf?direct=1 The main purposes of the proposed Bill will be to: Establish a legislative framework to enable information to be used to best effect to enhance medical care and patient safety; Facilitate the greater use of information technologies for better delivery of patient services; Underpin an effective information governance structure for the health system generally. Citizens Information Bureau, 35(10) Relate (2008). The Department of Health set out in its 2012 Strategic Framework, that the Health Information Bill will also provide a legal framework for the better governance of health information and the necessary enabling legal framework for a number of initiatives including health identifiers, data matching and health information resources (population registers). The Bill will also facilitate a standards based approach to health information management and to supporting inter-operability between computer systems. Campaigns (eg by DPOs) or Calls (eg in academic publications) for Accessible Medical Records No initiatives or calls specific to accessible medical records were found in researching medical/ health news websites, or DPO’s publications/ campaigns (such as the Disability Federation of Ireland, or associations for specific impairments). Additional Information about the Accessibility of Medical Records HIQA declare that in an Information Society, there is an increasing awareness of the value of personal information. However, HIQA declare that it must be managed properly in order to protect those whose information it is, and in order to maximise the potential benefits to be obtained from the collection and utilisation of such information. HIQA is charged with developing standards and monitoring these in respect of health information, under the Health act 2007. HIQA explain that the need for an information governance framework has been reiterated since it was first recommended in the 2001 Health Strategy, Quality and Fairness – A Health System for You, as well as being emphasised by the National Health Information Strategy of 2004, the 2008 Report of the Commission on Patient Safety and the Draft Health Information Bill. HIQA declare that at present the system of information governance in Ireland is: fragmented and lacks a cohesive structure that will reap the benefits and provide the safeguards of a fully functioning system. At a basic level a framework for IG protects people’s information and allows for high quality information to be used to improve patient safety, care and the health service generally. Health Information and Quality Authority, ‘International Review of Information Governance Structures’, (2009). Action 18 of the National Health Information Strategy 2004 anticipated the development of a framework for IG. Therefore, in 2009 HIQA conducted an international review of health information governance systems. The purpose of this was to examine how other countries have approached IG for health and social care settings. The Authority announced it would document which IG structures, policies, guidelines exists in the Irish health and social care sector. This will inform the Authority on how best to approach the development and monitoring of such systems when they are set up. Health Information and Quality Authority, ‘International Review of Information Governance Structures’, (2009). Here HIQA reports of a HSE Information Governance Framework project formed in April 2009 and that addresses: rights of privacy, confidentiality, consent and access to records, clinical ethics and professional standards/codes of practice, records management and the deployment of data standards and definitions, amongst others. Health Information and Quality Authority, ‘An “As Is” Analysis of Information Governance in Health and Social Care Settings in Ireland,’ (2010). The only published book to date in this area in Ireland is Protecting Personal Health Information in Ireland: Law and Practice which looks at the development of data protection law in Ireland in an international context and how it currently operates in the health system. It sees the major issue as one of reconciling increasing claims for use and disclosure of health information against long established patient rights to control their information. Important to note is that in 2014, the Health Identifiers Act was published. This Act will provide the basis for the development of a Health Identifier a unique record for not only patients but also clinicians and services. The non-transferable number will be assigned to everyone in Ireland and will last for a lifetime This will facilitate the development of improved EHR's (Electronic Health Records) will help to ensure that patient information is anonymised, reduce duplication and reduce potential cases of mistaken identity at the point of care. It will enable doctors and services to share patient information. The Healthcare Informatics Society of Ireland informs that this legislation has the potential to enable patients by improving access to their own records and thus move more care into the public health system. The extent of the accessibility within the Act does not relate to accessibility by persons with disabilities. Communications Between Medical Staff and Disabled Patients Obligations and Standards Mandatory/Binding Accessibility Requirements applicable to Relevant Communications In 2012 HIQA produced its National Standards for Safer and Better Healthcare aimed at protecting patients in health services. These standards will form the basis for future licensing of all healthcare facilities in Ireland and included a heavy focus on effective communication with service users. The following are only a few examples of how these Standards promote effective communication in the health services: Standard 1.6 addresses service user’s dignity, privacy and autonomy are respected and promoted, which includes communication with service users in a manner that respects their dignity and privacy (1.6.3.). Health Information and Quality Authority, ‘National Standards for Safer and Better Healthcare,’ (2012), 36. Standard 1.7.2. foresees that in practice health services must promote, ‘active listening and communication with service users in an open and sensitive manner, in line with their expressed needs and preferences.’ Ibid., 38. Standard 1.8. outlines that ‘service users’ complaints and concerns are responded to promptly, openly and effectively with clear communication and support provided throughout this process.’ Ibid,.40. In 2008, the Department of Health and the HSE developed a National Healthcare Charter. This Charter is called You and Your Health Service. The Charter outlines that public health and social care services are organized to ensure that everyone has equity of access and therefore patients can expect: Reasonable access to the most appropriate public health services regardless of physical, sensory or intellectual ability. With regard to communication the Charter expresses that these services endeavor to communicate openly and provide clear, comprehensive and understandable health information. Patients should be given: Information in a language that you can understand. Access to interpretative services where possible. Health Service Executive, ‘National Healthcare Charter,’ available at: http://www.hse.ie/eng/services/yourhealthservice/hcharter/National_Healthcare_Charter.pdf (accessed 12 August 2014). Part 7 of the Medical Practitioners Act establishes complaints procedures concerning registered medical practitioners. Section 69 of the Medical Practitioners Act 2007 provides that the Medical Council of Ireland may prepare guidelines for resolving complaints by mediation or other informal means. The Medical Council of Ireland informs that doctors must be aware that complaints may be made against them to the Medical Council on grounds of professional misconduct or other grounds, including poor professional performance, under the Medical Practitioners Act 2007. Medical Practitioners Act, 2007 www.irishstatutebook. ie/2007/en/act/pub/0025/index.html. This would include complaints based on unacceptable behavior or poor communication. Technical Accessibility Standards or Guidance relating to Relevant Communications Pursuant to Section 28 of the Disability Act 2005 all public sector information must be accessible. Therefore a public body is obligated to ensure that when it communicates with one, or more persons, that its communication is communicated in a form that is accessible. In response to this, and other parts of the Disability Act, the National Disability Authority has produced an accessibility toolkit for public sector staff. National Disability Authority, Accessibility Toolkit-for Public Sector Staff,’ available at: http://accessibility.ie. This toolkit addresses alternative forms of communication and provides guidance. The NDA, via its Centre for Excellence in Universal Design has issued guidelines in relation to electronically delivered services (IT Accessibility Guidelines, www.accessit.nda.ie) and the built and external environment. The Centre supports the implementation of eAccessibility and focuses on web accessibility and convergent communication and digital audio-visual media. The Centre provides web-accessibility techniques, as well as information on how to procure accessible IT solutions. For more details see: http://universaldesign.ie/guidelinesampstandards/ict Citing the relevant legislation, Disability Act 2005, Section 27 and 28, procurement regulations implementing Directive 2004/18/EC and the Equality Acts. the Centre has provided online guidance for online public services, which includes the online presence of the health sector and related bodies. See: http://universaldesign.ie/files/Universal_Design_for_Online_Public_Services.pdf. In 2005, the Equality Authority of Ireland, together with the Irish Pharmacy Union produced a practical advice document for Accessibility for Customers with Disabilities in Community Pharmacies. M. Gilber, ‘Accessibility for Customers with Disabilities in Community Pharmacies- Practical Advice,’ (2005). In its Guide to Professional Conduct and Behavior for Registered Medical Professionals, the Medical Council of Ireland discusses communication in terms of capacity to consent within patients. Medical Council of Irleand, ‘Guide to Professional Conduct and Behavior for Registered Medical Professionals’ (2009). In cases were informed consent to medical treatment can be sought, the Guide explains that as part of the informed consent process, patients must receive sufficient information, in a way that they can understand, to enable them to exercise their right to make informed decisions about their care. Ibid., at 35.2. The Medial Council understand that effective communication is the key to achieving informed consent, they advise that doctors must take appropriate steps to find out what patients want to know about their condition and what they ought to know about their condition, its investigation and treatment. The Guide advises that when providing information healthcare professionals: should consider patients’ individual needs and priorities. For example, patients’ beliefs, culture, occupation or other factors may have a bearing on the information they need to reach a decision. You should ask your patient whether they have understood the information they have received and if they would like more information before making a decision. Ibid., at 36.2. Litigation or Other Publicly Documented Complaints about Inaccessible Communications with Medical Staff The Office of the Ombudsman published an Investigation report to the Health Service Executive concerning complaints against the Public Health Service in 2012. Office of the Ombudsman, ‘Report to the Health Service Executive concerning complaints against the Public Health Service’, (2012), available at: https://www.ombudsman.gov.ie/en/Publications/Investigation-Reports/Health-Service-Executive/Report-to-the-Health-Service-Executive-concerning-complaints-against-the-Public-Health-Service/ (accessed 10 June 2014). Here, it addressed Communications recognising that: Good communications are an integral part of quality healthcare, not alone between patients and medical professionals but also between medical professionals themselves . . . Deficiencies in the communications practices of staff in acute hospitals have been identified in a recent survey of patients in acute hospitals, conducted by the Irish Society for Quality and Safety in Healthcare. The Survey found that approximately one in ten patients were not informed of their condition or treatment in a way that they understood and, at times, were given little opportunity to discuss these matters with members of their healthcare team. One in four respondents reported that they had questions that they would like to have asked members of their healthcare team, but did not, whilst the same number reported that staff discussed medical matters at their bedside whilst ignoring them. Failures in communications between healthcare professionals and their colleagues, and between professionals and carers, are the source of many complaints. Common problems include the provision of conflicting information, poor record keeping and a lack of involvement in care plans. The benefits of good communications for patients include a better relationship with the professional, higher rates of compliance with treatments and a heightened sense of empowerment in making decisions about their own health. Office of the Ombudsman, ‘Report to the Health Service Executive concerning complaints against the Public Health Service’, (2012), available at: https://www.ombudsman.gov.ie/en/Publications/Investigation-Reports/Health-Service-Executive/Report-to-the-Health-Service-Executive-concerning-complaints-against-the-Public-Health-Service/ (accessed 10 June 2014). The report of the Ombudsman further identifies that patients, in general, are vulnerable while in hospital and therefore, it is vital that all health professionals appreciate the patient's perspective, to make all exchanges appropriate and as sensitive as possible and to understand that effective communication means more than simply ‘saying something to somebody.’ Therefore, the Ombudsman declared that he would wish to see a special emphasis placed on the development of improved communication skills as one means of reducing complaints in the sector. Ibid. The Health Act 2004, provides for the establishment of a statutory framework for these complaints procedures. The statutory basis for the HSE complaints procedure became law in 2007 through Statutory Instrument 651/2006. The detailed Regulations, are contained in the Health Act 2004 (Complaints) Regulations – SI 652/2006. Under this statutory framework, the Health Service Executive must establishing procedures for dealing with complaints about the services it provides, or about those of other agencies that provide services on behalf of the HSE. See: www.healthcomplaints.ie. Following the above mentioned report, the Office of the Ombudsman issued a Statement of Good Practice for the Public Health Service in Dealing with Patients, which outlines the human rights and values to be respected by professionals and that, Every patient has the right to be fully informed about their health status, including the medical facts about their condition; about the proposed medical procedures, together with the potential risks and benefits of each procedure; about alternatives to the proposed procedures, including the effect of non-treatment; and about the diagnosis, prognosis and progress of treatment. . . . Information must be communicated to the patient in a manner appropriate to the latter's capacity for understanding, minimising the use of unfamiliar technical terminology. If the patient does not speak a common language, some form of interpreting should be available. . . . Ibid. Accessibility of Communications with Medical Staff in Practice Extent of Accessibility As noted above, the National Disability Authority has produced an Accessibility Toolkit to make public services more accessible, which includes healthcare services. Specifically Section 26 on Access to services. Section 30 of the Act stipulates that the NDA may provide Codes of Practice to implement the aforementioned sections. The toolkit addresses how to accommodate person with different disabilities. For customers with hearing difficulties the NDA suggests, for example: Provide queuing systems that do not rely on customers’ ability to hear; To help people who lip-read, make sure there is no shadow on your face while you speak; Provide induction loop systems—and test them regularly; Make captions available for videos, and make transcriptions available for audio information; Providing written versions of any audio notices and communications; Allowing customers to use text messages and e-mail to make appointments; Providing ISL (Irish Sign Language) interpretation to customers who request it; Making sure that only one person speaks at a time; When working with an interpreter; Talking directly to the Deaf person, and not the interpreter; Not asking the interpreter’s opinion; Making sure that the interpreter sits next to you and that the Deaf person can see both of you clearly. National Disability Authority, ‘Accessibility Toolkit- for public sector staff’, (2012). Here, the NDA also refer to the Irish Deaf Society that have produced a guide entitled: 10 Commandments For Communicating with Deaf Person for situations where a person cannot use ISL or where an interpreter is not present. The NDA toolkit also discusses how to best accommodate persons with other disabilities. They suggest for example that for clients that are anxious or depressed that services allow extra time for these and that they are allowed to bring an advocate, friend of family member to appointments and to encourage breaks. National Disability Authority, ‘Accessibility Toolkit’, available at: http://accessibility.ie/MakeYourServicesMoreAccessible/ (accessed 10 June 2014). In 2007 the NDA also produced some Recommendations for improving the accessibility of health services for people with disabilities in Ireland, in partnership with the HSE Disability Legislation Implementation Overseeing Group. These recommendations aimed to provide healthcare providers and planners with information about the barriers to accessing health services faced by people with disabilities and to suggest practical ways of overcoming these. Recommendations include the provision of accessible and appropriate information, services located within accessible buildings, disability awareness training for staff and to address the needs of people with disabilities in the event of emergencies. National Disability Authority, ‘Literature review on accessible healthcare that underpin the National Guidelines on Accessible Primary, Community and Hospital Services,’ (2012), 12. Accessibility in the Training courses of Medical Staff The Health Service Executive has produced employment legislation guidelines in which it recognises that ‘disability awareness training for staff helps to promote good communications, challenge preconceived ideas and stereotypes and foster a positive working environment in which the person can realise their potential.’ Health Service Executive, ‘Guidelines on Equal Opportunities Aspects for Employing People with Disabilities’, (2006), available at: http://hse.ie/eng/staff/Resources/Employment_Legislation_Guidelines/Guidelines%20on%20Employment%20of%20People%20with%20Disabilities.pdf (accessed 10 June 2014). Under the Medical Practitioners Act 2007, Section 88 (2)(i), the Medical Council has responsibility to prepare and publish guidelines on ethical standards and behaviour appropriate for medical students pursuing a course of study leading to the award of a basic medical qualification. To this end, the Medical Council has also produced Guidelines for Medical Schools on Ethical Standards and Behaviour appropriate for Medical Students. These were published to support medical schools and students in developing pre-registration professionalism. The Guidelines address the areas of competence, confidentiality, personal and professional interactions, dress and health. These do not address accessibility specifically, however, in student interactions with patients, the brief Guidelines state that they should treat all patients with courtesy and respect for their dignity, respect their views, and treat all patients equally, amongst others. Overall, the Guide refers to the more detailed Guide to Professional Conduct and Ethics for a more through deliberation and also specifies that it is the medical schools responsibility to ensure that the Guidelines on Students’ Ethical Standards and Behaviour are implemented. CORU is the National Regulatory Body that regulates the Health and Social Care Professions in accordance with the Health and Social Care Professionals Act 2005. In its Guide to the Code of Professional Conduct and Ethics Available at: http://www.coru.ie/uploads/documents/Professional_Conduct_and_Ethics.pdf (accessed 8 August 2014). it informs that each profession has its own Registration Board that has or will establish its own Code specific to their profession. The Registration Board are also responsible for monitoring education and training programmes. For example, the Speech and Language Therapists Registration Board launch its Code of Professional Conduct and Ethics Bye-Laws in 2014. The Code states that it is the registrants obligation to respect the rights of individuals to be heard and to be listened to and to have information made accessible to them. Further, registrants must always show, through their practice and conduct, respect for the rights and dignity of all individuals as identified under the Equal Status Act. Speech and Language Therapists Registration Board Code Of Professional Conduct And Ethics Bye-Law 2014. Under the 2007 Health Act the HIQA (Health Information and Quality Authority) is responsible for setting standards for all healthcare settings, this includes public and private hospitals and health care services. The resulting Standards for Safer and Better Healthcare (2013) outline that service providers are also required to support their workforce in respecting and promoting the autonomy of service users with disabilities, for instance through facilitating disability awareness training. Health Information and Quality Authority, ‘General Guidance on the National Standards for Safer Better Healthcare,’ (2012), 23. Good Practice Examples The Citizens Information Board run a Sign Language Interpreting Service to enable interpretation to deaf people in Ireland. In 2011, together with the HSE, and organisations representing deaf people, a working group came together to develop a policy for universals access for people who are deaf to all HSE services. This is to be used as a template for similar initiatives in other Government departments. Citizens Information Board, ‘Annual Report 2011,’ (2011), 33. In 2013 a new system called IRIS (Irish Remote Interpreting Service) was set up across Ireland. This is a skype-like system which provides interpreting services via the use of a computer screen and can be used anywhere with an internet connection without the interpreter having to be present, on site. The origins of IRIS stem from a 2006 report on sign language service requirements in Ireland. The report found that there were only 44 full- and part-time interpreters in the country working for a community of over 5,000. It also discovered that there was a major problem with access to those few interpreters, particularly rural communities. Currently the Irish Senate is discussing a Bill on the Recognition of Irish Sign Language for the Deaf Community. The second reading of the Bill was debated in January 2014. Ongoing Developments Commitments to Improvement The Quality and Patient Safety (QPS) Directorate of the Health Service Executive (HSE) was established in January 2011. The role of the QPS Directorate is to provide leadership and support the statutory and voluntary services of the HSE to provide quality and safe services to patients their families and members of the public. The Quality and Patient Safety Directorate supports the implementation of National Standards for Safer Better Healthcare adopted by HIQA, mentioned above in the acute hospital sector, National Ambulance Service and Primary and Community Care Services. Amongst many other standards that address accessibility, Health Information and Quality Authority, ‘National Standards for Safer and Better Healthcare’, (2012), 30. Standard 1.2 assures that Services users have equitable access to healthcare services based on their assessed need. This includes the requirement to identify the access needs of the population served, including their physical, sensory and language needs, and arrangements to meet these needs in line with relevant legislation. Health Information and Quality Authority, ‘National Standards for Safer and Better Healthcare’, (2012), 28. 2.3.2 Campaigns (eg by DPOs) or Calls (eg in academic publications) for Accessible Communications with Medical Staff The National Disability Authority in 2007 commissioned a research project together with the National Women’s Council of Ireland on Women with disabilities’ experience of the service provision during pregnancy, early childbirth and motherhood. National Disability Authority, ‘Pregnancy, Childbirth, early motherhood project’, available at: http://www.nda.ie/CntMgmtNew.nsf/DCC524B4546ADB3080256C700071B049/419BBFC356BC438A80257705003FA51D?OpenDocument (accessed 23 July 2014). The resulting reports provide a useful overview of the background and context of Irish disability policy, including a useful review of the Irish health services, generally. The review focussed on gathering research-based literature that involved both qualitative and quantitative data on the situation of women with disabilities; the review cited research in relation to Communication and found that: Irish research on the quality of communication between medical professionals and people with mental health difficulties found that an alarming proportion of the 471 respondents interviewed were uninformed about the medicine prescribed to them, its effects, and the possible alternatives open to them (Farrelly, 2002). Asking patients about their medicine, Farrelly found that 66% of patients were not given written information about its possible side effects, and only 37% were offered a choice of medication, with fewer women being offered this choice than men. National Disability Authority, ‘Exploring the Research and Policy Gaps: A review of literature on women and disability’, available at: http://www.nda.ie/cntmgmtnew.nsf/0/bf3a14b644017a648025729d0051dd2b/$file/womens_literature_and_disability_01.htm# (accessed 13 June 2014). The National Council for the Blind, Ireland (NCBI) has produced numerous guidelines with practical tips for health professionals, nursing staff, care staff, public health nurses and occupational therapists. These guidelines provide guidance on what to do prior to an appointment, going for an appointment, in the waiting room, offering medical advice, providing medical information, being admitted to hospital and going home. Available at: http://www.ncbi.ie/information-for/health-professionals. The Irish Deaf Society has produced a Basic Medical Signs document which is a guide for all Irish medical institutions on common medical sign-language for patient care. This includes a CD and booklet with photographs on signs that can be used in healthcare settings. Additional Information about the Accessibility of Communications with Medical Staff The HSE’s Quality and Patient Safety Directorate includes a Universal Access Office with a national specialist in Accessibility appointed within it. This person is responsible for the provision of guidance, advice and strategic support in the promotion of access for people with disabilities in mainstream health services and provide support for compliance with Part 3 of the Disability Act 2005 (on access to buildings and services). Health Service Executive, ‘Quality and Patient Safety Directorate’, (2013). Access Officers like this, across services are provided guidance in the Accessibility toolkit for public sector staff- mentioned above. National Disability Authority, ‘Accessibility Toolkit’, available at: http://accessibility.ie/MakeYourServicesMoreAccessible/ (accessed 10 June 2014). Generic Health-Related Information Obligations and Standards Mandatory/Binding Accessibility Requirements applicable to Generic Health Information In Ireland, the National Disability Authority’s (2006) Code of Practice on Accessibility of Public Services and Information Disability Act, 2005. S.I. No. 163 of 2006 refers and is entitled "Disability Act 2005 (Code of Practice) (Declaration) Order 2006, available at: http://www.nda.ie/cntmgmtnew.nsf/0/3DB134DF72E1846A8025710F0040BF3D?OpenDocument. provided by public bodies provides statutory guidance to public bodies on how to improve access to written information. The Health Service Executive is covered by this code. The Code outlines that public bodes should consider providing information in accessible formats, such as: Large Print; Braille; Electronic communications that can be accessed with adaptive technology; Audio tapes. The Code also provides detailed advice on how each public body can ensure that the information it publishes which is directly relevant to persons with intellectual disabilities, is made available to them in clear language that they easily understand, according to Section 28(3) of the Disability Act 2005. As regards Health related information, the Disability Act 2005 is relevant in the context of genetic information as this Act introduced a series of provisions dealing with genetic data and testing. The provisions in the Disability Act aim to ensure that people who may be affected by genetic disorders will not be subject to any unreasonable requirements from an employer or an insurance or mortgage provider. The protections provided are in addition to the substantial safeguards for the use of personal information contained in the Data Protection Acts. Other legal text that apply here are the Health Act 2007 and the Statistics Act of 1993. The 2007 Act which established the Health Information and Quality Authority and conferred certain information related functions on it as per the National Health Information Strategy (2004). The 1993 Statistics Act provides a statutory basis for the collection and use of specified information, including health information, and allows outside parties to be designated, under the Acts, to carry out certain research on the information collected. Technical Accessibility Standards or Guidance relating to Generic Health Information The National Disability Authority (2005) document, First Steps in Producing Accessible Publications, provides guidance on how to draw up accessible publications by planning accessibility through single source publishing. HIQA are developing Health Information Technical Standards to ensure that there is consistency in capturing and sharing of health information records. In July 2013, HIQA produced an Overview of Healthcare operability Standards. Health Information and Quality Authority, ‘Overview of Healthcare operability Standards,’ (2013), available at: http://hiqa.ie/healthcare/health-information/technical-standards (accessed 13 August 2014). In this overview of International practice and existing standards, HIQA informs that it has developed a standards development process which determines whether to adopt or adapt an existing standard or to develop a new standard in in Ireland. Ibid., 28. The Authority has so far published two messaging standards (messaging standards outline the structure, content and data requirements of electronic messages to enable the effective and accurate sharing of information) using HL7 v2.x with XML encoding: General Practice Messaging Standard The General Practice Messaging Standard is applied by Healthlink which is the national health messaging service which provides the electronic communication of patient information between primary and secondary care settings. Currently, the HL7 v2.4 standard is the specification used by Healthlink for the exchange of communication between GPs, Health services and hospitals throughout most of Ireland, available at: http://hiqa.ie/publications/general-practice-messaging-standard-version-20. and National Standard for Patient Referral Information. Available at: http://www.hiqa.ie/publications/report-and-recommendations-patient-referrals-general-practice-outpatient-and-radiology-. The Citizens Information Board (CIB) has a statutory responsibility to provide information to the public on state services and has developed guidelines on accessible information in 2009. Citizens Information Board, ‘Accessible Information for All,’ (2009). The CIB also provides people with disabilities with a national advocacy service, on the basis that advocacy can help to ensure equal access to services and information. Litigation or Other Publicly Documented Complaints about Inaccessible Generic Health-Related Information None identified. Accessibility of Generic Health Information in Practice Extent of Accessibility The only specific information guide relevant to the health sector prepared to date (and with the support of the Data Protection Commissioner) is the joint National GPIT Group, Irish College of General Practitioners and Irish Medical Organization Guide to Managing and Protecting Personal Health Information in Irish General Practice. The Guide was prepared specifically for use by general practitioners and indicates how they should manage patient information within the regulatory environment of laws and ethical codes. As general practice is at the heart of a considerable amount of patient information flows between different parts of the health system, the guide pays considerable attention to the rules governing such communications. Good Practice Examples In 2001 Anna May Harkin prepared a report on the Equity of Access to Health Service- Some relevant issues in an Irish Context, as a background paper for the Working Group on the National Anti-Poverty Strategy (NAPS) and Health. Anna May Harkin, ‘Equity of Access to Health Service- Some relevant issues in an Irish Context,’ (2001). In the report the author identifies that the readability of health information leaflets published in Ireland is low and therefore inaccessible to a large amount of the population, especially those with low literacy skills. Ibid. 24. The National Adult Literacy Agency (NALA) conducted an audit project in 2010 together with the HSE. The outcome was a literacy audit tool for healthcare settings. The health literacy tool aims to enable a person to understand health information, whether this is provided in person, over the telephone or in a written format. NALA has produced two information kits on certain health conditions and on how to write information that is easy to understand, targeted at health services. National Adult Literacy Agency, ‘NALA Audit Project 2010,’ (2010), available at: https://www.nala.ie/sites/default/files/publications/NALA%20Audit%20Project%20Dec%202010%20report_1.pdf (accessed 14 August 2014); see also: https://www.nala.ie/literacy/literacy-in-ireland/policy-priorities/health. Ongoing Developments Commitments to Improvement HIQA published a paper in December 2011 entitled Developing National eHealth Interoperability Standards for Ireland: A Consultation Document. Its purpose was to inform key stakeholders including service users, suppliers, purchasers and implementers of eHealth applications, healthcare providers and any other interested parties about the proposed future direction of eHealth standards in Ireland, and to encourage wider participation in standards development. The work outlined a set of key principles to guide the Authority’s work in this area, and this overview of healthcare interoperability standards has been undertaken as a recommendation following the consultation process. Health Information and Quality Authority, ‘Overview of Healthcare operability Standards,’ (2013), available at: http://hiqa.ie/healthcare/health-information/technical-standards (accessed 13 August 2014). In the National Disability Strategy Implementation Plan 2012-2013, the Irish Government set out that it will ensure the delivery of disability and mental health awareness training to staff, particularly frontline staff, including through NDA e-learning training module, so that customer services are better tailored to needs of customers with disabilities. This will be targeted at all government departments and public bodies under their aegis. Department of Justice, ‘National Disability Strategy, Implementation Plan 2012-2013’, (2012). The Implementation Plan also announces that the government will encourage service providers to develop health promotion programmes for persons with disabilities. Specifically, the HSE will encourage all service providers to develop health promotion programmes for people with disabilities. The aim, according to the Plan, is to facilitate better access to mainstream health screening programmes for people with disabilities have and to support people with disabilities in managing their own health. Ibid. Campaigns (eg by DPOs) or Calls (eg in academic publications) for Accessible Generic Health-Related Information In 2008, a group of Speech and Language Therapists working on a national level with adults with intellectual disabilities set up an Accessible Information Working Group. In 2012, the group produced a guide to producing easy-to-read information targeted at agencies and health and social care settings and to promote a consistent approach. See: http://www.fedvol.ie/Accessible_Information_Working_Group_launches_Make_it_Easy__a_guide_to_producing_easytoread_materials/Default.1775.html. Additional Information about the Accessibility of Generic Health-Related Information Dental Council of Ireland checked Irish Nursing and Midwifery Board checked Irish Health and Social Care Professionals Council checked Medical Council checked Health Promotion Ireland checked In 2012, the NDA commissioned a report on the review of the literature on accessibility in healthcare that underpin the National Guidelines on Accessible Primary, Community and Hospital Services that are in its draft stages. Once in operation these standards are set to help healthcare providers meet their statutory responsibilities under the Equal Status Acts, the Disability Act 2005 and associated statutory Code of Practice; provide practical information to staff working in healthcare so they can meet the particular needs of service users with disabilities, including those relating to the service itself, to communication, to information, and to premises and equipment; serve as a reference manual for staff; will be used in education and training in relation to disability, accessibility and customer care and they will assist Access Officers in public health services in their statutory role to provide, arrange for and coordinate assistance and guidance to persons with disabilities who want to access their services. J.Pillinger, NDA, ‘Review of literature and guidelines on accessibility in healthcare that underpin the National Guidelines on Accessible Primary, Community and Hospital Services,’ (2012). Medical Equipment Obligations and Standards Mandatory/Binding Accessibility Requirements applicable to Medical Equipment The regulation of medical devices in Ireland is largely driven by EU Legislation, of which the applicable law is set out in the Medical Device Directive 93/42/EEC. National legislation transposing this Directive (as amended) includes the European Communities (Medical Devices) Regulations 1994 (S.I. 252/1994) (as amended in 2001, 2002 and 2009). Within the healthcare arena the National Standards Authority of Ireland (NASI) list three committees that work on accessibility standards in relation to medical equipment: Healthcare Standards Consultative Committee (HCSC), following the work of relevant CEN and ISO committees; Health Informatics Standards Consultative Committee (HISC), (HISC follows the work of the relevant ISO TC 215 and CEN TC 251- standardization in the field of Health Information and Communications Technology (ICT)); See: http://standards.cen.eu/dyn/www/f?p=204:32:0::::FSP_ORG_ID:6232&cs=18CA078392807EDD402B798AAEF1644E1. Electrotechnical Council of Ireland (ETCI) TC 10 Electrical Equipment in Medical Practice. THE NSAI refers to one overarching internationally recognized standard ISO 13485 for certification in Ireland which provides a comprehensive management system for the design and manufacturing of medical devices. Technical Accessibility Standards or Guidance relating to Medical Equipment In its Annual Report, the NSAI report that it has a Accessibility for All Standards Consultative Committee, the scope of which is to advise NSAI in regard to the need for National standards in the area of universal design and accessibility for all, including persons of any size, age, ability or disability. See: http://www.nsai.ie/NSAI/files/aa/aa04310d-fa90-4e41-95d2-7937d87c071c.pdf. ETCI has produced guide and national rules of relevance that are available for purchase n their website: Electricity in the Medical Workplace: An Educational Guide for Users of Electrical Equipment in Medical practice; National Rules for Electrical Installations (4th Edition). Available at: http://etci.ie/publications/onlinestore.html. The HSE has produced a Medical Devices/Equipment Management Policy (Incorporating the Medical Devices Management Standard). This is to ensure that a formal system to manage medical devices is established in the HSE to set uniform policy, standards and procedural guidance that is implemented to support the development of a system and a coordinated management of Medical Devices / Equipment throughout the organisation. Health Service Executive, Medical Devices/Equipment Management Policy (Incorporating the Medical Devices Management Standard),’ available at: http://www.hse.ie/eng/about/Who/archive/medequip.pdf. The policy promotes the use of a standards based approach for a safer, efficient, and high quality management of all medical devices/equipment. This Policy and management standards should be read in conjunction with the HSE’s Medical Device/Equipment Procedural Guidance, which outlines that its main elements are, amongst others, communication and consultation. Criterion 9 of the Medical Devices/Equipment management policy instructs that the manufacturer is responsible for issuing clear and accurate instructions for the safe use of Medical Devices. The HSE’s guidance on this issue also outlines that manufacturers must ensure that information on storage, pre-use checks, use, maintenance and cleaning should be passed on to the end user (even through second ownership). A failure to pass on this information/ the original instructions may ‘compromise the end user’s ability to use the device safely, and may leave the provider open to legal liability.’ Ibid. Also, some users or carers with particular disabilities or medical conditions may need additional instructions or training. For example, people who are visually impaired may not be able to easily read some forms of written information. The responsible organisation may also need to supply its own information to explain any additional administrative arrangements e.g. contact details for maintenance, consumables or spare parts. Health Service Executive, ‘Medical Devices/Equipment Management,’ (2010), 15. Litigation or Other Publicly Documented Complaints about Inaccessible Medical Equipment None identified. Accessibility of Medical Equipment in Practice Extent of Accessibility The HSE have developed a Hygiene and General Medical Equipment portfolio to implement its Management of Patient Equipment Standard, to progress compliance with this standard and to assist staff in accessing user guide, cleaning instructions and other relevant information to medical equipment. This portfolio is available on desktops of computers in all ward areas. See: http://www.hse.ie/eng/about/Who/qualityandpatientsafety/QPS_goodpractice/hygieneequip.html While the Standard does refer to people with disabilities as end-users, the portfolio folder does not indicate any particularly reference to ‘disability.’ However, the HSE explain in its Tender Competition rules that in regard to specification requirements for purchasing products or services on behalf of the HSE, which includes medical devices, these will generally be formulated by reference to recognised standards or in terms of performance or functional requirements. The HSE outline that it is intended that these will define all required characteristics such as quality levels, environmental performance, design (including accessibility for disabled persons), dimensions, product use, fire, safety, infection control, and packaging. Health Service Executive, ‘Tender Competition Rules,’ (2012). Good Practice Examples None identified. Ongoing Developments Commitments to Improvement Campaigns (eg by DPOs) or Calls (eg in academic publications) for Medical Equipment to be made Accessible Consultations and research with people with Spinal Cord Injuries Spinal Injuries Ireland, ‘The Reality of Living with a Spinal Cord Injury,’ (2004); Spinal Injuries Ireland; Spinal Injuries Ireland, ‘The Experiences of Living with a Spinal Cord Injury in Ireland: the physical and psychological impact,’ (2009). (Spinal Injuries Ireland 2004 and 2009) show that, amongst others improved access to equipment for mobility, was needed for people with Spinal Cord Injuries. Story M F, Schwier E and Kailes J I (2009) Perspectives of patients with disabilities on the accessibility of medical equipment: Examination tables, imaging equipment, medical chairs, and weight scales. Disability and Health Journal. 2(4),169-179. (US based study). Additional Information about the Accessibility of Medical Equipment No further information. Telemedicine Services Obligations and Standards Mandatory/Binding Accessibility Requirements applicable to Telemedicine Services There are no mandatory or binding accessibility requirements in Ireland, in relation to telemedicine as there is no legal basis for the provision of telemedicine. However, health policy is increasingly recognising the importance of ICT, including telemedicine services, in reforming and modernising the Irish health services. The key principles in the National Health Strategy Quality and Fairness: A System For You are: equity, people-centeredness, quality and accountability. This Strategy announces the development of primary care services that will be improved as these are the first point of call and vitally important in rural parts of Ireland. ICTs are considered pivotal. However, at most, Ireland has only applied ad hoc provision of telemedicine specifically, and only on an experimental basis and with limited sustainability. A. MacFarlane, A.W. Muphy and P. Clerkin, ‘Telemedicine services in the Republic of Ireland: AN evolving policy context,’ (2006) Heath Policy 76(3), 245. Technical Accessibility Standards or Guidance relating to Telemedicine Services Based on the above, none identified, other than that found in the Guide to Professional Conduct and Behavior for Registered Medical Professionals, in which the the Medical Council of Ireland discusses Telemedicine and explains that: The practice of medicine through web-based telemedicine sites or other telecommunication methods requires clear adherence to principles of confidentiality and data protection. If you practice by such means, you must have strong security measures in place to protect the privacy of patient information. Web-based telemedicine sites must make their information policies clear to users. If you provide telemedicine or other telecommunication services to patients within the State, you must be registered with the Medical Council. . . . To help patients to understand telemedicine, you should explain to them that there may be aspects of telemedicine that are different to traditional medical practice, for example a consultation involving physical examination. Medical Council of Ireland, ‘Guide to Professional Conduct and Behavior for Registered Medical Professionals’ (2009). Litigation or Other Publicly Documented Complaints about Inaccessible Telemedicine Services None identified. Accessibility of Telemedicine Services in Practice Extent of Accessibility Not Identified. Good Practice Examples In 2013 the Irish medical News reported that consultants and GPs in Ireland are to participate in three pilot care delivery projects based on a US telemedicine initiative called Project ECHO (Extension for Community Healthcare Outcomes) that helps promote care in underserved and remote areas. http://echo.unm.edu/. ECHO provides primary care providers with training in medical conditions that would otherwise be treatable only by specialists, through a model of ‘guided practice’ and mentoring using video-conferencing technology. The aim is to reduce consultant waiting times and allow patients to be diverted from hospital services to be managed in the community. Available at: http://www.imn.ie/index.php?option=com_content&view=article&id=5426:ireland-becomes-eu-hub-for-new-healthcare-project&catid=61:news&Itemid=28. In Ireland to date, there are some limited trials in the area of telemedicine services. Enterprise Ireland, BioBusiness, ‘Connected Health in Ireland: An All Island Review’, (2010), available at: http://www.cardi.ie/userfiles/Connected_Health_in_Ireland_An_All_Island_Review.pdf (accessed 9 June 2014). As regards ICT in general, computer-based/electronic assistive technologies are not extensively available beyond occupational or educational contexts. A study by Enterprise Ireland (Enterprise Ireland is the government organization responsible for the development and growth of Irish enterprises) has found that the provision and availability of assistive technologies depends on the local and community supports in place, this can differ widely across the country. In general, Enterprise Ireland finds that the focus in relation to independent living for older people has tended to be low-tech rather than high-tech or ICT-oriented. Some relevant trials listed in their study include: The Technology and Dementia Project involved implementation of a range of devices and systems, including automatic clocks/calendars, alerting systems for doors and stairs, automatic lighting systems; automatic cooker shut-off devices and adapted telephones for easy use by people with dementia. These systems were implemented in 12 homes. The evaluation results were positive and continuation of the approach was recommended. No further development to date within mainstream services has occurred, however, although a new initiative on telecare has been run by the Alzheimer Society. Ibid. The study elaborates that mobile healthcare, referred to as mHealth is the application of wireless technologies and mobile services for use in the provision of healthcare. The study identifies that due to the ubiquity of mobile phones mHealth is a hugely expanding (market and research-) arena and examples of its benefits include: Remote access to information by healthcare workers; Mobile health related applications e.g. diagnostics and ePrescription; Mobile data collection and transmission for use in provision of care; Health and wellness applications to encourage health and prevent illness; Communications to and from patients. Ibid. Also, the United Nations has also developed the mHealth alliance to tap into this technology for healthcare uses in emerging markets. Another example highlighted by the study: A Limerick-based software development group called DOCTOT, which stands for ‘Doctor’s Tools of the Trade,’ has developed iPhone applications aimed at allowing doctors to use the most up-to-date download technology to access diagnostic aids during consultations. DOCTOT is producing a series of Applications with the support of a number of pharmaceutical companies. The first of these, DOCTOT Depression, already available on iTunes App Store, is a suite of the most widely used, clinically administered, depression assessment scales. Clinicians can use the App during a consultation whilst recording patient responses and then automatically generating scores that aid the diagnostic process. The App also allows uploading of these results on to computerized patient management systems so that results can be easily stored and accessed. Enterprise Ireland, BioBusiness, ‘Connected Health in Irleand: An All Island Review’, (2010), avilabel at: http://www.cardi.ie/userfiles/Connected_Health_in_Ireland_An_All_Island_Review.pdf (accessed 9 June 2014). Ongoing Developments Commitments to Improvement The National Health Information Strategy (NHIS) Department of Heath and Children, ‘National Health Information Strategy,’ (2004). focuses on health information and recognizes the potential for telemedicine systems to limit travel for patients and to increase the accessibility and efficiency of some services. This Strategy refers to HIQA to implement the actions under it. A 2006 Government report of the Expert Group on Mental health Policy, A Vision for Change, makes the recommendation that, facilities for videoconferencing and telemedicine should be considered to extend the expertise located in these [community health] units nationally, and to enable them to become a consultation and training resource. A Vision for Change, RECOMMENDATION 15.6.3 Campaigns (eg by DPOs) or Calls (eg in academic publications) for Accessible Telemedicine Services Telehealth Consultant Mel Healy, published a report in 2013 on Telemedicine in Ireland assessing Policy and Applications. She found that the process of reviewing the health care system of the past 5-10 years has led to a significant volume of documentation of a policy or strategic nature. However, the evidence is that both the recognition and policy treatment of telehelathcare, telemedicine and/or telecare ‘is inconsistent and patchy at best.’ M. Healy, ‘Telemedicine in Ireland: Policy and Applications’, (2013), available at: http://www.sedda.ie/news&events/2013%20Jul-Sept/Mel-Healy-Telemedicine/Mel-Helay_Telemedicine.pdf (accessed 9 June 2014). Scholars, MacFarlane, Muphy and Clerkin identify in their research on the evolving policy context of Telemedicine services in there is, however, a dearth of research about telemedicine in Ireland. A. MacFarlane, A.W. Muphy and P. Clerkin, ‘Telemedicine services in the Republic of Ireland: AN evolving policy context,’ (2006) Heath Policy 76(3), 245. This is why the researchers choose to provide the first systematic review of telemedicine in the two regional health boards in the Republic of Ireland. They find that, it appears that the development of telemedicine in the Republic of Ireland has been unplanned. A national telemedicine strategy might lead to an integrated national network in the future, which could help to provide more equitable access to health care. Maher, L. Craig, A. Menezes, g. ‘ A National Survey of Telemedicine in the Republic of Irleand’, 13(7) Journal of Telemed and Telecare (2007), 348. Additional Information about the Accessibility of Telemedicine Services In Ireland the positive influence of telecare and telehealth on health care recipients was recognised with the 2012 publication of The National Carers’ Strategy: Recognised, Supported, Empowered. The strategy states: The positive role of telehealthcare (telehealth, telecare and telemedicine) in supporting carers is being increasingly recognised. It can improve the experience of care for the care recipient and carer by reducing the need to travel to receive care and treatment and by facilitating better prevention, anticipatory care and earlier intervention. This use of such technology is particularly useful in remote and rural areas for both redressing isolation and for alleviating the sense that the carer must assume sole responsibility all of the time for care recipient. Department of Health, ‘The National Carers’ Strategy: Recognised, Supported, Empowered’, (2012). The National Carers’ Strategy also outline the importance of accessibility: Accessible housing and the built environment enable carers to support the person that they care for to live independently and safely in their own homes and communities. Having the right equipment, adaptations or telehealthcare in the home can also lessen the physical impacts of caring. Ibid. The Positive Ageing Strategy in, launched in 2013, noted the potential of new technologies for supporting older people to live independently at home. The strategy also noted that technologies can play an important role in chronic illness or disability prevention, as well as in the management of health conditions. Department of Health, ‘The Positive Aging Strategy’, (2013). Under the National Development Plan for 2007-2013, the Health Information and Communications Technology subprogramme outlines that Telecare and Telemedicine are areas of development in Ireland. Therefore. The National Programme identifies that the HSE will employ advance ICTs to help with communication between patients and doctors. Future Health – A Strategic Framework for Reform of the Health Service 2012–2015, published in November 2012, presents a vision of a safe, quality, equitable and accessible health service for the people of Ireland. Proposed reforms involve the potential focal area of TeleHealthcare. See: http://www.hse.ie/ictreform/. The HSE’s National Service Plan for 2014 does not mention Telemedicine. 39