#Interoperability & National Systems Statement: Australia

DIS-AU-029 | Version 1.0.0 | Last Modified On 01 August 2026

The Australian fork of DIS-GL-029 and the Australian analogue of the integration boundary published for India (DIS-GL-024). This document is the honest conformance answer. It states what is built, what is not, and what each unbuilt item would take.

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#Applicability

Conformance status is a property of the software, not of where it runs. The one exception is the processing-location constraint in Section 4, which is a property of where Pensieve's people are.

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#Purpose

To let an Australian hospital's CIO decide, in the first call rather than in week three, whether the deal it is contemplating is a fourteen-day deal or a nine-month one, and to make the distinction sellable rather than embarrassing.

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#1. The answer in three sentences

There is no Australian licence, registration, certification or approval a software vendor must hold to sell, install, operate or be paid for a hospital operating system in a private hospital. There are five government conformance programmes, and each one gates connecting to a specific national system, not selling. Pensieve holds none of the five, and the entire Australian go-to-market rests on that distinction being stated at qualification rather than discovered at cutover.

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#2. Conformance status: what is built, what is not

None of the five conformance programmes is required to sell, install, run or be paid for a hospital operating system. All five are required to replace a specific incumbent capability.

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#3. The two tracks, stated so a buyer can choose

Pensieve sells Track A today, says so in the first call, prices it accordingly, and records the excluded national systems on the Order Form as an express exclusion. MSA-AU-001 AU-11.8 is the contractual form of that boundary.

Two qualification questions decide the track, and they belong in the first conversation:

1. Does the hospital require Pensieve to lodge Medicare or ECLIPSE claims at go-live?
2. Does the hospital author its own pathology or diagnostic imaging written reports?

A "yes" to either makes the deal Track B. A hospital that answers yes to the second has a statutory upload obligation Pensieve cannot discharge, and must retain a system that can (DIS-AU-008 Section 6).

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#4. My Health Record

Status: Pensieve is not connected, is not on the Register of Conformity, and does not hold a Notice of Connection.

What it would take, in order:

1. Submission of vendor product details to the Agency, declaring the intended connection.
2. Notice of Connection testing against the Healthcare Identifiers Service and against the My Health Record system, using the Agency's test data pack.
3. Vendor-driven conformance testing against the conformance test specifications, concluding in a conformance vendor declaration.
4. Evidence submission and an observation session against the Connecting Systems Security Conformance Profile, which sets a minimum cyber security baseline for any clinical information system using the My Health Record business-to-business web services and is being phased in by vendor cohort.
5. An Australian-resident support tier with technically enforced separation of the My Health Record data plane.

Step 5 is the one that is not an engineering task. Section 77 of the My Health Records Act 2012 prohibits a registered contracted service provider from processing or handling information relating to My Health Record records outside Australia, with imprisonment among the penalties. Pensieve's engineering and support function is in India. A contractual promise, an encryption control or a data processing agreement does not satisfy that provision. DIS-AU-033 Section 4 states the position in full and MSA-AU-001 AU-11 is the operative restriction.

Pensieve therefore does not offer My Health Record connectivity and will not represent to a hospital, a tender or the Agency that it does. A hospital that requires it should treat it as a roadmap item with a hiring and identity-architecture dependency measured in months.

The direction of travel is one-way. From 1 July 2026 pathology and diagnostic imaging written reports must be uploaded to My Health Record within the prescribed period, subject to documented exceptions, and further categories have been announced. The set of information that must reach My Health Record is expanding, and Pensieve treats connectivity as a dated roadmap commitment rather than an indefinite exclusion.

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#5. Healthcare identifiers: the non-collection boundary

Pensieve does not collect, store, adopt, use or disclose Individual Healthcare Identifiers.

This is the same architectural move Pensieve publishes for India's national digital health programme, and it is stated the same way: affirmatively, deliberately, without apology.

Why. The Healthcare Identifiers Act 2010 limits the purposes for which identifiers may be collected, used, disclosed and adopted, imposes data quality and security obligations, and attaches criminal and civil penalties to unauthorised handling. Connecting to the Healthcare Identifiers Service requires the hospital's organisation identifier, a NASH PKI certificate, and software that has passed conformance Pensieve does not hold.

What follows for the product, and each is a real engineering rule:

1. An Individual Healthcare Identifier is not a general-purpose patient identifier. It is not the internal primary key, is not exposed in a URL, an export, an analytics extract or a log, and is not adopted as Pensieve's own identifier.
2. Where identifier handling is ever built, visibility is limited to roles with a permitted purpose and every access is logged.
3. Data quality obligations would require validation and revalidation against the Service, not free-text entry.

Until then: the hospital must not enter an Individual Healthcare Identifier into a free-text field, and DPA-AU-001 Section 6.4 records the handling if one arrives.

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#6. Credentials: the hospital's, not Pensieve's

Every connection to an Australian national system is authenticated with a credential issued to the hospital, not to the vendor.

Pensieve operates a bring-your-own-credential model. It calls national and third-party systems as the hospital, on the hospital's own authority, using the hospital's own credential. Pensieve is not the registered participant, does not hold those credentials in its own name, and does not represent that it does.

Custody, encryption, rotation, revocation, scope of use and destruction on offboarding are governed by ADD-GL-007 and described in DIS-GL-025. The Australian credential names differ; the model does not.

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#7. FHIR and AU Core

AU Core is the Australian profile set defining the minimum expectations on FHIR resources for Australian implementations, developed by the national FHIR accelerator and published under HL7 Australia governance, on FHIR R4. There is no register, no conformance test and no legal requirement for a private hospital's software to be AU Core conformant. It is a soft expectation that is appreciating quickly, and it is the cheapest credibility purchase available in an Australian technical conversation.

Pensieve's position and its status:

Pensieve labels this self-assessed, every time. A self-declaration described as a certification is the single fastest way for an uncertified vendor to lose an Australian technical reviewer.

Why it is worth doing. A published CapabilityStatement is a machine-checkable artefact. It answers the "will we be locked in" question better than any contractual exit clause, and it positions the hospital for the national health information exchange programme without Pensieve committing to a conformance programme it has not started.

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#8. Terminology and code systems

The global position (which terminologies the Platform carries, which version, and how versions are managed) is DIS-GL-029 Section 2 and the Terminology and Code System Version Register it names. The Australian editions the Platform must be configured to are SNOMED CT-AU, the Australian Medicines Terminology, and the Australian LOINC subset used in pathology reporting, and the register records the version in use for each Australian tenant.

Pensieve does not maintain these terminologies and is not their publisher. Licensing of the Australian editions to the hospital is the hospital's, obtained through the national terminology service, and is a bring-your-own-credential item under Section 6.

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#9. Claiming: the real Australian product gap, stated plainly

To lodge Medicare claims, private health insurer claims through ECLIPSE, or immunisation encounters, the software must be built against Services Australia's specifications, pass integration testing and receive a Notice of Integration. Only software holding a Notice of Integration may transmit claims.

ECLIPSE is the one that matters for a private hospital, because it carries the combined Medicare and insurer claim in a single transaction: in-patient medical claims, eligibility checks and hospital claims. A hospital operating system that does revenue cycle in Australia and cannot lodge an ECLIPSE claim is not doing the whole of revenue cycle in Australia.

Pensieve's honest position: this is a multi-quarter engineering programme against a government test harness, free of charge and expensive in time. For the first Australian deals the hospital retains its existing claiming path, and Pensieve:

• prepares the claim to the point of lodgement, with the coding, eligibility data and supporting documentation assembled;
• exports it in the format the hospital's existing claiming system accepts; and
• reconciles the remittance back into the Pensieve revenue cycle.

This is said in the first call. It is the difference between a scoped deal that goes live in weeks and a failed one that does not.

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#10. Electronic prescribing and secure messaging

Electronic prescribing. Pensieve holds no conformance. For an inpatient-only scope (prescribing, administration and pharmacy supply inside the hospital), no national conformance applies. For community or discharge prescriptions, conformance to the national prescription delivery infrastructure is required and Pensieve does not have it. The hospital retains its existing path.

Secure messaging. Pensieve holds no conformance. Clinical correspondence is exchanged by the transport mechanisms in DIS-GL-029 Section 1 and by the hospital's existing secure messaging provider, to which Pensieve delivers documents. This is a soft expectation, not a gate.

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#11. What Pensieve does with the security conformance profile today

The security baseline the Agency applies to systems connecting to My Health Record is aligned to the Essential Eight. Pensieve is not in that programme. The relevance is sequencing: the Essential Eight work Pensieve does for ordinary commercial procurement is the same work that would later underpin Agency security conformance. It is the one place in the Australian programme where a free early action buys down a later expensive one. Pensieve's self-assessed maturity position, per control, with dated gaps, is in REG-AU-002 Section 4.

The Essential Eight has been announced for retirement and replacement by a new series, with retirement beginning in 2027 and completing around 2028, and existing investment stated by the issuing authority not to be made redundant. REG-AU-002 Section 4 records that transition and Pensieve's re-baselining commitment.

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#12. The integration boundary: what stays with the hospital

The responsibility matrix, the sequencing and the acknowledgement the hospital signs are the Australian equivalent of DIS-GL-026, and are recorded on the Order Form as express exclusions so that no hospital is surprised at go-live.

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#13. Limitations

1. Every elapsed figure in Section 2 marked [ESTIMATE] is exactly that. Pensieve has not run any of the five programmes. Do not quote them to a hospital as commitments.
2. Conformance status changes. This document is the status as at the Last Modified On date, and REG-AU-002 carries the live position.
3. AU Core conformance is self-assessed. No independent assessment and no register listing exists.
4. Pensieve holds no fee schedule for Agency conformance and has not confirmed one [UNVERIFIED: the Agency does not publish a fee schedule; confirm directly if this ever becomes a funded programme.]
5. The claiming figures in Section 3 are engineering estimates without a primary source. REG-AU-002 Section 6 carries verification with an Australian practice-software vendor as an open item.

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#Related documents

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#Change history