26 November 2025
CHF welcomes the opportunity to provide a submission to the Department of Health, Disability and Aged Care’s (DHDA) Review of My Health Record Legislative Instruments.
In the context of CHF's commitment to improving digital health services, CHF supports and recognises the importance of ensuring that My Health Record legislative instruments are appropriate, current, robust and fit for purpose.
The key purpose of My Health Record (MHR) is to provide consumers with a secure, online, personal health summary. This is a system designed for consumers, and as such any significant changes to the system must be informed by meaningful consultation with consumers.
Unfortunately, the very short timeframe of the consultation period for the legislative review and the lack of specific resourcing for consumer consultation means we are unable to consult with the wider community to provide DHDA with in-depth and broad consumer input on this important legislation. We strongly recommend that future consultations allow appropriate time and resources to enable meaningful consumer input into the development and implementation of digital services designed to service them. To build trust in the system and ensure that reforms to My Health Record are fit for purpose it is essential that government prioritises consumer engagement.
Given the significant time and resource limitations, CHF engaged an existing consumer panel to provide input into this consultation. As part of our contract with the Australian Digital Health Agency (the Agency), CHF facilitates a Digital Health Project Consumer Panel (the Panel). The Panel consists of thirteen (13) healthcare consumers, with a diversity of backgrounds and experiences. The Panel has already made recommendations to the Agency in relation to My Health Record including potential improvements to user interface and accessibility, and suggestions for promotional and educational materials and resources. They have also provided feedback on the recent Share by Default legislation amendment (CHF’s submission on this topic can be found online here).
To inform this submission CHF consulted directly with Digital Health Project Panel members. We have also incorporated consumer feedback gathered in other forums, including a recent pilot research project undertaken for the Australian Digital Health agency investigating young people’s engagement with My Health Record, and data from CHF’s recent National Consumer Sentiment Surveys.
Consumer feedback on the key consultation questions is provided below. The consultation questions have been modified in places to make them clearer, more relevant and easier to understand. Consumers also fed back to CHF that the background information to the consultation was lacking useful details, such as data on current consumer uptake of certain processes or features (such as assisted registration).
Consumers are not a homogenous group and even within this small sample feedback was varied. While there was clear consensus on responses to some of the key questions, others received mixed feedback. We have summarised the feedback below for DHDA’s consideration and included direct quotes from consumers (Digital Health Panel Members) within the text.
Overall, consumers are generally happy with the current MHR legislative instruments – although they do have a number of suggestions for changes and improvements. This warrants broader and more in-depth consumer consultation to ensure any legislative changes accurately reflect consumer needs.
