By applying to participate in the present CEF eHealth DSI call, Cyprus and the respective NCPeH agree to adhere to the principles laid down in :
- the Governance model for the eHealth Digital Service Infrastructure during the CEF financing
- the Guidelines for an Organisational framework for NCPeH
- the Multilateral Legal Agreement (as soon as available)/Service Level Agreement
- any other relevant other policy or governance document adopted by the eHN.
In order to succeed in preparing, setting up, deploying and successfully operating the Cyprus’ NCPeHs, a robust governance model has been put in place including governance bodies dealing with policy governance, IT governance, secretariat functions and stakeholder liaison.
The governance structure comprises the following bodies:
- The eHealth Network, the eHealth Policy Owner: it steers the policy relevant to the eHealth Digital Service Infrastructure, and is assisted in that by the JASeHN. On the basis of the initial audit report to which an NCPeH will be subjected, the eHN will decide on the admission (or not) of a NCPeH to join the EU network, and on the continued participation. It meets twice a year, once in the 2nd quarter and once in the 4th quarter.
- The eHealth Operational Management Board (eHOMB): its main function is to make tactical and operational decisions about the eHDSI, oversee the building of core elements and maintain the close links to MS and NCPeH. It reports to the eHN and is assisted by a MS Expert Group. It meets on a quarterly basis.
- eHDSI MS Expert Group (eHMSEG) : has as main role to advise on core elements and link to building of the national elements. It can be convened in 3 configurations depending on the topic: technical, semantic or organization. Each configuration meets twice a year –ad hoc meetings may be convened if required.
The critical risks that may hamper the achievement of the objectives of the proposed Action are fully described on Risk Assessment section hereinafter. Even so, the points highlight the most critical risks regarding managing and governance:
- Untimely exchange of input between different governance bodies;
- eHN is unable to take decisions or postpone decisions to next eHN meeting;
- eHOMB has insufficient resources to allow them to fulfill their consulting and advisory role between eHN and Expert Group;
- eHMSEG members abstain from taking unanimous decisions due to purely national context related arguments.
Cyprus has initially identified the list of risk below to which actions will be planned in case they occur.
|Description of possible risk||Impact*||Probability of occurrence||Remedial actions|
|Legal ambiguity that may impede the exchange of clinical data||redesign||50%||Adopt, as soon as possible, a Multilateral Legal Agreement|
|Not having a functional /compliant technical solution for the NCPeH||Delays, cost overruns||25%||Adopt the OpenNCP Reference Implementation|
|Not being able to produce all the sections on the Patient Summary or ePrescription||cancellation||50%||Intervene at National Infrastructure level to create the foundational conditions, namely by creating structured clinical data encoded with standards.|
|Not having in place CEF eHealth Core Services (namely: Terminology Server and the Configuration Server)||Delays, redesign||25%||Use the central service solution as it was providing during epSOS and EXPAND.|
|Not being able to obtain from the National Data Protection Agency authorization to cross border exchange of clinical data||cancellation||25%||Better understand how can EU law and Directives support and fundament the request for authorization.|
|Untimely exchange of input between different governance bodies
|Possible delays and loss of information||50%||Define precise information exchange procedures and have a clear orchestration process.|
|eHN is unable to take decision or postpones decisions to next eHN meetings||Delays, high impact on entrance in operation||25%||Strong coordination and follow up activity eHOMB is required|
|eHOMB has insufficient resources to allow them to fulfill their consulting and advisory role between eHN and Expert Group||Severe delays, cancellation, jeopardise the complete governance process||75%||Refine and accurately define eHOMB role and supply it with sufficient resources to assure this governance body can fulfil its mission.|
|eHMSEG members abstain from taking unanimous decisions due to purely national context related arguments||Delays, redesign, advice from eHMSEG to eHOMB is blocked||25%||Clear decision policy must be defined.|
|Low Citizen and/or Health Professionals engagement||Delays and lower the impact/benefits of the services||20%||Plan the right dissemination strategy to reach the Citizen and/or Health Professionals according to specific national characteristics of the stakeholders.|
*Possible impact: delays, cost overruns, cancellation, redesign, etc
The Cyprus NCPeH will closely liaise with the Expert Group, to whom it will delegate an expert for each of the three domains (semantic, technical and organizational). Cyprus will intensively participate in eHN activities to ensure proper information flow at a political level.
Cyprus will adhere and cooperate under the “Governance model for the eHealth Digital Service Infrastructure during the CEF funding” endorsed by the eHN. Regarding the management structure at National level, this will follow a functional schema which is outlined below, and it is supported initially (in Phase 1) by a subcontractor at technical level (Gnomon Informatics has been pre-selected for this tasks based on the extensive and unique experience in the field. The Ministry of Health supported by the UCY experts will provide the overall eHealth strategy and policy coordination. The whole effort which will lead to applications will be supervised by the Ministry of Health. A Project Management Board will be established to steer and coordinate the project at the strategic level. The local management structure is proposed as follows and this will be discussed with the rest of the project management structure in order to become less bureaucratic.
Management structure and procedures
The project management and administration is designed in such a manner to allow for effective decision making, efficient internal and external communication, as well as effective administrative, financial and scientific control and monitoring of the project.
Local Project Management Board (LPMB) and The Local Scientific Advisory Board (LSAB).
LPMB is responsible in matters of planning, strategy, commitments and conflict resolution. This includes continuous monitoring of the project’s progress, associated risks and accomplishments and setting up reliable and smooth communication. To achieve this, the board will undertake the following roles:
- Organizational Management, performing management activities related to the project’s organizational structure, financing and resource planning, dealing with legal and ethical issues and general maintenance of the consortium agreement. Under this role, the committee will appoint Work Package and Task Leaders, ensuring efficient management across all levels of the project.
- Risk Management, performing risk identification and analysis, generating contingencies and executing contingency actions to avoid impacting the project and continuous monitoring of identified risks.
- Communications Management, its main tasks being the setup of reliable and fluid communication channels between partners of the consortium.
The committee will meet to report on the project’s status and progress always with representatives of each of the other management groups as well as the Work Package leaders. Meetings can be either teleconference-style (i.e. using a platform such as Skype or Google Talk or even normal landlines) or physical face-to-face meetings.
LSAB is tasked with providing scientific and technical consultancy throughout the project’s activity. Furthermore, it will constantly monitor advancements in the relevant scientific and technological fields and provide valuable feedback to the Risk Management body to the LPMB.
Besides these two main management boards, we have the following roles assigned: Local Project Coordinator, Local Project Administrator and Work Package Leaders. They are responsible to interact with the two boards defined above, for achieving the good management of all the activities of the project. In particular their activities are described below:
Local Project Coordinator: The general management is held by the project coordinator, who is in charge of the correct execution of the contract; consolidate the periodic reports, project deliverables and other reports using the inputs from the Work Packages Leaders WPL or partners. Other duties include: 1) Monitoring and control of the time schedule and the timing of the related scientific activities through implementation of an effective tracking system; 2) Editing and forwarding formal project reports to the project coordinator; 3) Ensuring timely release and accuracy of deliverables; 4) Editing meeting agendas and minutes of the local project meetings; 5) monitoring and mitigate any possible risk during the whole period of the project;
Local Project Administrator: will be responsible for dealing with contractual, financial and administrative issues, and to coordinate administrators from all participating institutions. The PA’s duties include 1) Interface with the European Commission; 2) Management of the legal, contractual, financial and administrative issues of the project;
Activity Leaders: They are senior technical or scientific members of the staff of the partners. The Activity leader will be responsible for the detailed coordination, planning, monitoring and reporting of the deliverables within their work package.
The management procedure will be the following:
Reporting & Internal Information Flow
An internal network will be established among the project partners to facilitate and to promote opportunity for work and team development.
Progress of the project: The progress of the Project will be closely monitored by checking the successful completion of the well‐defined tasks into which the objectives are divided against a schedule of dates agreed by the partners.
Quality control and assurance:
Quality control and assurance procedures will allow flexibility while maintaining a clear distinction of roles of bodies involved. A number of internal and external control procedures and mechanisms are foreseen to allow for quality control and assurance on the project’s progress and results. These include (a) a detailed risk management mechanism, (b) an internal assessment method such as SWOT (Strengths, Weaknesses, Opportunities and Threats) or PEST (Political, Economic, Social and Technological) analysis and (c) quality control and assurance procedures such as project reviews and audits.
Conflict resolution: The consortium already has a good working relationship from previous collaborations amongst partners in collaborative projects at varying levels. It will be the goal of the consortium to avoid any unnecessary conflicts; nevertheless, if they arise, correct procedures must be put in place to deal with them accordingly.
Risk Management: To react to possible problems, continuous assessment and evaluation the various phases of the project will be performed by the Project Management Board for the early recognition of risks and elaboration of adequate contingency plans. As a whole, risk management will follow the following phases: Identification and its assessment; risk management, risk solving.
For monitoring progress, assessing results and developing NCPeH into operation strategic planning helps ensure that internal and external communication function stays relevant and responsive to the needs of the eHDSI. Some action points outlined below will define the communication strategy:
- Determine the present situation. Ensure alignment with EU, Regional and National Strategies by understanding where it currently stands and where leaders want to take it. A SWOT analysis will be performed.
- Talk to key stakeholders. Short Interviews with key stakeholder will be scheduled to learn what their priorities are.Gaining a good understanding of business issues will allow the project to offer effective solutions.
- Future state vision. Foresee how communication function needs to operate at least one year from project start.
- Prioritize vision elements. Identify the elements from Step 3 that are most important to the business.
- Revisit the objectives. The project will pick the three to six vision elements and turn them into actionable objectives.
- Develop and prioritize potential strategies and tactics. A range of potential strategies will be created to achieve each of these objectives.
- Define metrics, timelines and responsibilities. This step is about establishing the details behind those strategies and tactics.
- Develop strategic and tactical plans. This step will consolidate the wealth of ideas generated, and integrate them into a document with clear responsibilities for the project team and other stakeholders, for management review and approval.
- Implementation and beyond. Once the strategic communication plan has been launched, the project management team will determine regular review cycles for all phases of the plan. Ideally, the plan should be reviewed in a group meeting once every quarter, assessing all elements of the plan and their outcomes.
Cyprus will cooperate under the Governance model for the eHealth Digital Service Infrastructure during the running of the CEF project as endorsed by the eHN. Cyprus will adopt and follow the Guidelines on an Organizational Framework for eHealth NCP. These guidelines will follow an overall strategy and action plan in line with the other Member states. This will be part of Activity 4 Task 4.2.
Cyprus will have no other choice but to create and maintain a Master Transaction Catalogue (MTC), and the national part of the Master ValueSet Catalogue (MVC). As described in Activity 1 Task 1.5, via common terminology adoption defined in MVC and their translation and transcoding. Also clinical documents in HL7 CDA V2 Level 3 structured and coded according to the EC Guidelines and the associated implementation Guides. Having done these will reassure semantic interoperability of PS and eP.
Cyprus is able to design, set up and implement a TRAINING program for professionals as described in Activity 4, Task 4.1, Specific communication and educational sessions will be organized in order to inform and train the Health Professionals (physicians who generate the Patient Summaries and ePrescription, emergency ward personnel, pharmacists.
Cyprus can design, set-up and implement an evaluation strategy to measure national USAGE and IMPACT from cross border eHealth services provision.
The Cyprus Project Management structure is described on the table below.
|NCPeH – Organisation||UCY and MOH will organise the NCPeH at a Regional level|
|NCPeH – Contact person||Contact person to be appointed by the MOH.|
|NCPeH – Technical responsible||UCY will appoint a technical responsible for its NCP in liaison with MOH.eH|
|NCPeH – Security responsible||UCY will appoint a security responsible|
|NCPeH – Help desk||MOH will ensure an operational Heldesk for the project. A specific procedure for the NCPeH will be provided for this purpose.|
|Directive 2011/24/EU NCP||Compliance is already assured at a National level|
|Legal Expert||MOH and UCY will appoint a legal expert for the project.|
|Patient Consent Administrator||Patient consent will be managed centrally by eHealth Platform in Cyprus|
|Involvement of National Data Protection authority||Cyprus (EPITROPOS PROSTASIAS PROSOPIKON DEDOMENON) Data Protection Authority will be consulted prior to service deployment into operation as one of the key steps for both internal and external auditing.|
|Patients´ identification confirming authority||To be managed by MOH and eGevernance strategy in Cyprus.|
|Health Professionals’ identification confirming authority||eHealth platform being designed will secure the HCP identification in Cyprus to establish treatment relationship confirmations between doctors and patients.|
|National Clinical Document (PS/eP) specification & management Team||Are being taken care of MOH|
|Terminology Expert (MVC Management)||The MOH and NCPeH with a terminology service to be introduced will assume that role.|
|Translation team (MTC Management)||The MOH and NCPeH with a translation service to be introduced will assume that role|
|National Standardisation Bodies||The Bureau for Standardisation in Cyprus is responsible for developing standards in Cyprus. In addition, this body will be asked to organise training on the use of the required standards.|
|Internal Security Auditor||UCY in collaboration with eHealth Platform will ensure internal security auditing in compliance with eHN/eHOMB guidelines. This task may be subcontracted to a competent independent body.|
|External Security Auditor||Cyprus will comply to eHOMB/eHN decisions on the external audit. External subcontracted entities will be used for this task.|
|Marketing – responsible for delivering the right information to patients and Professionals||MOH in collaboration with UCY and local professional medical bodies will take care of this task.|
|Educator – responsible for training professionals while providing cross border services||MOH and UCY will lead this task as depicted in Activity 4 of the project.|
|Evaluation – responsible for gather the evidences and measure impact at national level||An evaluation framework will be developed by MOH and UCY and applied in order to measure at national level the impact.|