Comments to the European Commission audit report ref. DG(SANTE)/2018-6522-MR

Ref. 6-2/12-5 26.04.2018 ANNEX I Comments to the European Commission draft audit report ref. DG(SANTE)/2018-6522- MR of the audit carried out from 12 March 2018 to 16 March 2018 in order to assess the Estonian National Contact Point for eHealth's readiness for joining the Cross Border eHealth Information Services Network. No Reference Comment to the audit report 1. Section: 5.5 We ask you to reconsider or rephrase the finding no 25 and the Semantics recommendation no 25. The self-assessment provided with the audit Page: 6 request included the following information in regards to the criteria SI.9: The HCP feedback collecting will be done via helpdesk. Helpdesk will be the Section: 8 single contact point for Estonian HCPs (in this case pharmacists). This will Recommen allow us to collect the feedback about the service though one channel and dation have better overview of it. A specific type of incident should be created for Page: 11 the general feedback collecting if possible. At the moment no other channel will be provided to the HCPs but it will remain an option to be rediscussed during the start of the operation whether the HCPs wish to provide immediate feedback more easily and what would be the form of this (structured feedback, free text, how can we ensure enough detail about the issue to make any assumptions or perform any investigation on this etc). During the audit it was also explained by HWISC that all of the feedback in regards to the planned cross-border service (and in regards to all other already existing services) will be collected through the HWISC Help Desk and a separate incident/service request type in regards to this is planned. No separate channel is planned for this at the moment. With the separate channel the aim was to describe that there might be a need to collect additional feedback from the health care professionals during the operation in regards to aspects of the service, for example such as the overall clarity of the information on the ePrescriptions. Since there might be cases where the feedback requires investigation (in case there is a reason to believe that there might be errors in the document transformation process, for example) and thus can be classified as an incident, it is important that all feedback is registered in the Help Desk incident management system. The HWISC Cross-Border Service Manager will be responsible for making sure that also the general feedback from health professionals is analysed and that the necessary actions in regards to this is taken. 2. Section: 5.3 We propose to clarify the link between the finding no 11 and the Operations recommendation no 11. The finding refers that Change Management and procedure should cover all changes such as changes in the organisational Services set up. However, the recommendation limits the focus of the process Page: 4 improvement only to cover the usage of change management procedure for correcting the underlying cause of incidents/problems. Section: 8 At the moment we find that the finding can be widely interpreted and Recommen perhaps needs to be narrowed to match the recommendation. dation Page: 9 3. Section: The report explains the abbreviation eHMSEG as „eHealth Digital Service Abbreviatio Infrastructure Member State Expert Group“, however according to the ns and 1  Ref. 6-2/12-5 26.04.2018 Definitions Governance model for the eHDSI, adopted by the eHealth Network, the Used in abbreviation is defined as „eHealth Member State Expert Group“ This Report Reference: eHDSI Glossary, Page: III https://ec.europa.eu/cefdigital/wiki/display/EHOPERATIONS/eHDSI+Glossa ry 2