Skip to main content

National Digital Health Mission

Introduction​

Aimed at digitising the citizens’ complete health records and portfolio, the National Digital Health Mission //2 was launched by the Prime Minister of India, Narendra Modi, in his address //1 at the 74th Independence Day on 15th August, 2020, and was piloted in six Union Territories – Andaman and Nicobar, Chandigarh, Dadra and Nagar Haveli and Daman and Diu, Ladakh, Lakshadweep, and Puducherry.//15 The National Health Authority, //3 an office of the Ministry of Health and Family Welfare, has been tasked with “the role of designing strategy, building technological infrastructure and implementation of “National Digital Health Mission'' to create a National Digital Health Eco-system.” //4

Strategy Document​

[**INSERT DOCUMENT LINK] //**

When the National Digital Health Blueprint was released in July 2019, there was a mention of the significance for establishing the NDHM for digitising India’s health ecosystem. Subsequently on 7th August 2020, a strategy document was released, outlining the NDHM’s vision. According to PM Modi, “Every Indian will get a Health ID card. Every time they visit a doctor or a pharmacy, or a lab, all the details will be registered in this health card. Ranging from doctor appointment to the medication prescribed, medical tests, when were they done, every bit of detail will be available in your health profile.” //5

The roll-out and implementation of the Health Data Management Policy, particularly of unique health identification cards through the Ayushman Bharat Health Account, is a key focus of the NDHM.

Unique Health Identification under the NDHM​

The Health Data Management Policy was first approved on 14th December 2020 as the next step to digitise healthcare ecosystems. The first draft termed the national Health ID as Unique Health Identification or UHID, which was to be voluntarily issued after verification through a valid government identification document, such as the AADHAAR. Within the first two week of its launch on 15 August 2020, health IDs were created for 55,700 individuals under the NDHM. //11 The Unique Health Identifier Rules//8 were notified on 1st January 2021, and they stated its purpose as follows: “UHID will facilitate integration of health data across various applications and create longitudinal Electronic Health Record (EHR) for citizens besides allowing de-duplication in various health services provided by Ministry.”

Chapter IV in both drafts of the HDMP highlights how the Health ID shall be created, allocated, and used, with Section 16.1 of the second draft //12 specifying the platforms for ABHA number creation: “The IT platforms which are integrated to ABDM (through sandbox environment) can be utilized for creating ABHA number for individuals.” Section 17.3 of the first draft //10 had clarified the following Health ID creation process:

“A data principal may create his/her Health ID by:

(a) accessing such web-based portal as may be specified by the NDHM;

(b) verifying his/her identity through Aadhaar or other means as may be specified by the NDHM;

(c) filling in the other details that are required on such portal; and

(d) enrolling for a Health ID.”

Notably, the voluntary nature of seeking a UHID was associated with the claim that the “failure or refusal to make use of Aadhaar would not result in the denial of access to any health facility or service under the policy.”//6 Under the National Digital Health Mission (NDHM), Aadhaar based verification will be used to authenticate UHIDs on a voluntary basis. Details to be collected include //9:

  • Health Data - Diagnostic reports, discharge summaries, clinical notes, prescriptions, immunisation records
  • Personal Data - Name, age, sex, household size, Aadhaar
  • Sensitive Personal Data - Financial information, Sex life, Sexual orientation, Biometric data, Genetic data, Transgender status, Intersex status, Caste or tribe, Religious or political belief or affiliation

However, the second draft //7 of the HDMP, released for public consultation on 23rd April 2022, referred to the Ayusman Bharat Health Account or ABHA, which was the new term for UHID, changed on 13th January 2022. While the previous version of the HDMP provided that “a data principal may request for the creation of a Health ID at no cost”, the latest version reads “ABHA (number) may be created at no cost,” notably taking away the agency from the patient to decide whether or not to get an ABHA number (Clause 15.1).

The ABHA is envisioned to be a repository for every Indian’s health-related information with participation from various healthcare providers like hospitals, laboratories, insurance companies, pharmaceutical providers, among others.

  • Various healthcare providers — such as hospitals, laboratories, insurance companies, online pharmacies, telemedicine firms — will be expected to participate in the health ID system.
  • Every patient who wishes to have their health records available digitally must create a unique Health ID, using their basic details and mobile or Aadhaar number.
  • Each Health ID will be linked to a health data consent manager, which will be used to seek the patient’s consent and allow for seamless flow of health information from the Personal Health Records module.
  • The Health ID will be voluntary and applicable across states, hospitals, diagnostic laboratories and pharmacies.

Criticism of the UHID​

There was widespread criticism for the unique health ID system when media reports highlighted the use of the Co-WIN portal to automatically generate digital health IDs for people without their explicit knowledge or consent. //38 //42 //43 _The Quint _reported in June 2021 when the first COVID vaccination doses were being provided to the majority of Indians: “Many Indians who took the jab said they have no idea how the ID is generated. Several took it to social media platforms to point out that there was no ‘consent’ taken or information provided to the users before the generation of the UHID.” //39 In February 2021, _The News Minute _reported:

“On January 27, a circular was issued by the Puducherry Directorate of School Education directing schools to instruct parents to create Health ID for “all school-going children and their families”. The circular was based on a directive from the Puducherry Directorate of Health and Family Welfare issued on January 9.” //44

This adds to the controversy at the heart of unique health identifiers globally as experts in Germany tout it as “one of the main stumbling blocks in the development of national health card project” and it is deemed as a “privacy-invasive tool of eHealth”. //40 As health digitisation through unique health identifiers essentially links multiple forms of information to one another, there have been concerns of surveillance and privacy violations through the administration and private entities, as such health IDs have “a huge power of identification”. //41