The National Digital Health Strategy: What It Means for Private Providers

Private providers should treat Australia’s National Digital Health Strategy as a practical operating mandate, not a policy document. It raises expectations for secure information sharing, standards-based interoperability, privacy controls, and measurable benefits. Providers that align early can reduce integration cost, improve continuity of care, and strengthen compliance posture. Providers that delay will face rising onboarding friction from referrers, payers, and digital health platforms.

Definition

What is the National Digital Health Strategy and why does it matter?

Australia’s National Digital Health Strategy (2023–2028) sets a national direction for a connected, digitally enabled health system, coordinated across jurisdictions and implemented with industry and provider participation.¹ For private providers, the strategy translates into higher baseline expectations for identity, data exchange, cyber security, and patient-centric information flows, particularly where services span primary care, acute, diagnostics, allied health, and aged care.¹

The strategy is reinforced by companion plans and reporting, including an Action and Impact Report that tracks roadmap progress.² This matters because procurement, commissioning, and clinical integration increasingly reference national priorities. In practice, the strategy affects your technical roadmap, your compliance obligations, and your commercial positioning in referral networks and value-based models.

Context

Why is Australia pushing a digital health roadmap toward 2025 and beyond?

Australian governments are trying to reduce fragmentation caused by siloed systems, manual handoffs, and uneven data quality. The National Healthcare Interoperability Plan (2023–2028) sets out 44 actions across identity, standards, information sharing, innovation, and benefits measurement.³ This places interoperability outcomes into the mainstream of national delivery, not as an optional IT enhancement.

In parallel, the Australian Government’s Digital Health Blueprint and Action Plan (2023–2033) describes a ten-year vision for “trusted, timely and accessible” digital and data use across health and wellbeing, complementing broader national and jurisdictional strategies.⁴ For private providers, this means the “digital health roadmap 2025” is less about a single date and more about an accelerating sequence of requirements and market norms across 2024–2028.

Mechanism

How does the strategy change day-to-day operations for private providers?

The biggest operational change is a shift from document exchange to standards-based, permissioned information sharing. The national interoperability plan emphasises consistent identity foundations and standards adoption.³ The Sparked program, Australia’s HL7 FHIR Accelerator, exists to accelerate national FHIR standards and implementation guidance, signalling that API-based exchange will become more common.⁵˒⁶ FHIR itself is designed as a standard for exchanging healthcare information electronically, and it supports modern integration patterns that are easier to govern than bespoke interfaces.⁷

Governance expectations rise alongside connectivity. Participation in My Health Record carries obligations under the My Health Records Act 2012 and the My Health Records Rule 2016, including requirements for a written Security and Access Policy (Rule 42) that is communicated and enforced.⁸˒⁹ The Office of the Australian Information Commissioner (OAIC) also makes clear that health service providers must embed privacy and take active measures to protect personal information, including “reasonable steps” for security under APP 11.¹⁰˒¹¹

A practical implication is that “digital health” becomes a clinical risk and trust program, not just an IT program. Workforce training, access governance, audit readiness, and vendor management become core operational controls, especially where systems connect to national platforms and external messaging networks.

Comparison

What is different from earlier digital health programs?

Earlier phases often focused on digitisation within organisational boundaries, such as internal electronic medical records, eReferrals, or point solutions for patient engagement. The current direction is system-level alignment. The interoperability plan formalises cross-sector actions and benefits measurement at a national scale.³ The blueprint extends this with a ten-year view of connected care experiences and modern foundations.⁴

The other difference is the growing maturity of standards pathways. Sparked is explicitly structured to advance FHIR standards through community co-design and published outputs.⁵˒⁶ This reduces uncertainty for providers deciding which standards to prioritise and strengthens the business case for investing in reusable integration assets instead of one-off interfaces.

Applications

What should private providers do first to align with the strategy?

Start by treating interoperability as a product capability with governance, not as an integration backlog. A sensible sequence is:

1. Baseline compliance and trust controls
   Confirm Rule 42 artefacts, training, and audit trails for My Health Record participation.⁹ Align your privacy management to OAIC health privacy guidance and APP 11 security expectations.¹⁰˒¹¹ Map third-party access, data flows, and retention rules to reduce risk in connected settings.

2. Standards-led integration roadmap
   Prioritise FHIR-aligned use cases where feasible, especially for high-friction transitions of care such as referrals, discharge, diagnostics, and medication information.⁵˒⁷ Use the national interoperability plan as the reference for identity, standards, and information-sharing priorities.³

3. Patient communication and consent at scale
   As information sharing increases, the operational burden shifts to clear patient communications, consent workflows, and consistent messaging across channels. Where the organisation runs multiple brands, locations, or service lines, a centralised measurement and insight layer helps detect friction and risk early. Customer Science Insights can support this by consolidating customer experience and operational signals into decision-ready insights for leaders and service owners: https://customerscience.com.au/csg-product/customer-science-insights/

This approach reduces rework because it links national direction to the operational reality of process change, technology change, and workforce adoption.

Risks

What can go wrong if providers move too fast or too slow?

Moving too fast can create uncontrolled information sharing and inconsistent privacy practice. OAIC guidance emphasises that handling health information appropriately underpins trust and requires practical privacy steps embedded in operations.¹⁰ Without role-based access discipline and consistent training, connected systems increase the blast radius of errors.

Moving too slow can lead to escalating onboarding friction. Referrers, hospitals, payers, and digital health networks increasingly expect secure messaging, standardised identifiers, and interoperable outputs. The national interoperability plan positions benefit measurement as a priority area, which can shift commercial discussions toward demonstrable outcomes rather than intent.³ This can disadvantage providers who cannot evidence reduced manual handling, improved continuity, or lower avoidable rework.

Cyber security is an additional risk amplifier. The ACSC Essential Eight is a widely used baseline for making compromise harder and is supported by maturity models and assessment guidance.¹² A provider can be clinically excellent yet commercially constrained if cyber maturity blocks integrations, data sharing, or partner trust.

Measurement

How should private providers measure progress and prove value?

Measurement should link national direction to executive outcomes: safety, speed, cost-to-serve, and trust.

Interoperability performance

• Percentage of key workflows using standards-based exchange rather than manual upload, fax, or email, aligned to interoperability actions and priorities.³

• Time-to-integrate new partners, measured from contract signature to live exchange, to quantify integration reusability.⁷

• Data completeness for transitions of care, tracked by missing fields and reconciliation workload.

Privacy and security posture

• Rule 42 policy coverage, staff completion rates, and audit findings closure time for My Health Record participation.⁸˒⁹

• APP 11 “reasonable steps” evidence, such as access logging, incident response rehearsal, and supplier assurance.¹¹

• Essential Eight maturity targets for relevant systems, measured via consistent assessment methods.¹²

Clinical and service outcomes
Evidence remains heterogeneous in published studies, so providers should use consistent internal outcome measures rather than relying on a single external benchmark.¹³˒¹⁴ Focus on duplication reduction, avoidable follow-up contacts, and reduced clinician time spent chasing information.

Next Steps

What is a pragmatic 90-day plan for leaders?

A realistic first quarter should deliver governance confidence and a clear build sequence.

Weeks 1–4: Governance and baseline readiness
Confirm My Health Record participation obligations, Rule 42 artefacts, and privacy posture.⁸˒⁹˒¹⁰ Establish a single, executive-owned interoperability backlog mapped to the national interoperability plan priorities.³

Weeks 5–8: Prove one high-value exchange pathway
Choose a workflow with measurable friction, such as imaging results distribution, referrals, or discharge follow-up. Implement standards-led exchange where feasible, and design reporting that shows time saved and exceptions reduced.⁵˒⁷

Weeks 9–12: Scale measurement and adoption
Expand the workflow to additional sites or partner organisations. Train staff, monitor exceptions, and treat adoption as a service quality program.

Providers that want external support to turn national requirements into operating rhythms can use CX Consulting and Professional Services for delivery governance, controls design, and measurable rollout planning: https://customerscience.com.au/service/cx-consulting-and-professional-services/

Evidentiary Layer

What evidence supports the direction toward interoperability and stronger controls?

National policy and implementation artefacts consistently emphasise connected care, standards, identity foundations, measurable benefits, and secure information sharing.¹˒³˒⁴ Sparked provides an implementation pathway for national FHIR standards and evaluates progress and impact, signalling maturity in the standards ecosystem.⁵˒⁶ Privacy and My Health Record governance materials define operational requirements that private providers must treat as ongoing controls, not one-off compliance tasks.⁸˒⁹˒¹⁰˒¹¹ Cyber guidance provides a practical baseline for reducing compromise risk in connected environments.¹² Peer-reviewed reviews reinforce that interoperability benefits depend on implementation quality and that outcome measures vary, supporting the need for disciplined internal measurement.¹³˒¹⁴

FAQ

What does the strategy mean for a private hospital group with multiple brands?

It increases the need for consistent identity, privacy, and information-sharing controls across brands, plus a standards-led integration roadmap aligned to national interoperability priorities.¹˒³

Do private providers have to adopt FHIR to comply?

No single standard is mandated in every context, but national interoperability efforts and Sparked outputs increasingly make FHIR the practical path for scalable, governed exchange.⁵˒⁷

What is the minimum governance requirement to participate in My Health Record safely?

Maintain compliance with the My Health Records Act and the My Health Records Rule, including a written, communicated, and enforced Rule 42 Security and Access Policy, supported by staff training and access controls.⁸˒⁹

How should leaders balance data sharing with privacy risk?

Use OAIC health privacy guidance to embed privacy in processes, and apply APP 11 “reasonable steps” controls such as access governance, logging, retention discipline, and incident readiness.¹⁰˒¹¹

What should a diagnostics or allied health provider prioritise first?

Secure messaging and consistent information sharing patterns, paired with strong privacy controls and measurable reductions in manual handling and turnaround delays.³˒⁹

How can providers scale staff adoption without creating training fatigue?

Treat adoption as operational change with role-based learning, workflow prompts, and searchable knowledge assets that keep policies and procedures current. Knowledge Quest can support this by structuring and operationalising knowledge so staff can execute compliant, consistent processes at speed: https://customerscience.com.au/csg-product/knowledge-quest/