IT for Change's Response to the NHA Consultation Paper on the Unified Health Interface

IT for Change recently responded to the call for consultation by National Health Authority (NHA) and National Digital Health Mission (NDHM) on the Unified Health Interface (UHI).

ITfC deems the creation of digital public goods in the health sector a critical imperative and appreciates the NDHM’s initiative in setting up the UHI. However, we assert that it is equally vital that the governance of the UHI be strengthened at an early stage while the blueprint is still being laid out.

Read the full text of our submission here.

The key points of our submission include:

  1. The National Digital Health Mission (NDHM) must adopt appropriate safeguards and prescribe clear guidelines for access to, and use of, the UHI in the development of digital health services. These measures are necessary to prevent the private capture of the benefits of public digital health infrastructure by dominant platform companies.
  2. A tiered pricing model for the usage of the UHI must be put in place. This model must distinguish between public sector agencies, non-profit entities, digital start-ups in the domestic health services sector, and large gatekeeper platforms.
  3. NDHM must continue to govern the UHI in the long term and parallel private sector gateways should not be created in order to prevent the risk of a closed platform ecosystem from re-emerging in the health services sector.
  4. Clear guidelines and rules must be established to govern the use and re-use of aggregate and personal data being generated through the applications in the UHI ecosystem – including but not limited to the personal data protection framework.

Read the text of our complete submission to the NHA here.


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