In-depth policy study of the current state of eHealth in

Georgia, Moldova and Ukraine

Funded by: EU

Conducted by: International Business and Economic Development Association

Research lead:

Research team:

January 2022,
PREFACE

This research study is part of the project called: Synergy of e-Health and digital skills in Georgia,
Ukraine and Moldova: the path to increase resilience of EaP civil societies in crisis times; (Grant
Contract number: 005/2021/Lot2/002).
Contents
Key Terms and Definitions........................................................................................................................4
1. Introduction............................................................................................................................................5
1.1 Background.......................................................................................................................................5
1.2 Objectives and Tasks........................................................................................................................5
1.3 Expected Results...............................................................................................................................5
2. Research methodology...........................................................................................................................6
2.1 Assessment Approach.......................................................................................................................6
2.2 Respondents and sources................................................................................................................10
3. Research Findings and Recommendations..........................................................................................11
3.1 eHealth Legislation and Policy......................................................................................................11
3.1.1 Policy and Strategy..................................................................................................................11
3.1.2 Regulation of eHealth field......................................................................................................16
3.2 eHealth Governance.......................................................................................................................24
3.3 eHealth Infrastructure and Services..............................................................................................32
3.3.1 HIMS modules.........................................................................................................................46
3.3.2 Other Separate systems............................................................................................................48
3. 4. Innovation and Research in eHealth...........................................................................................53
3.5 Capacity, Competence, Resources..................................................................................................54
3.6 International Cooperation, Projects, Initiatives............................................................................56
4. Media Analysis..................................................................................................................................58
5. Annexes................................................................................................................................................69
Annex 1: Information Sources,............................................................................................................69
Annex 2: Questionnaires,.....................................................................................................................69
Annex 3: Transcripts............................................................................................................................72
Key Terms and Definitions

HMIS – Health Management Information Systems

DSM - Digital Single Market

EaP - Eastern Partnership

EC - European Commission

EU - European Union

HER - Electronic Health Record system

ePrescription – Electronic Prescription System

eID - Electronic Identification

GDPR - General Data Protection Regulation

HDM - Harmonization of Digital Markets

HIV/AIDS - Human Immunodeficiency Virus /Acquired Immune Deficiency Syndrome

ICT - Information and Communication Technologies

IoT - Internet of Things

MoIDPOTLHSA - Ministry of Internally Displaced Persons from the Occupied Territories, Labor,
Health and Social Affairs of Georgia

NCDC – National Center of Disease Control and Public Health

ITA – Information Technology Agency

NHA – National Health Agency

USAID - United States Agency for International Development

WHO - World Health Organization

1. Introduction
1.1 Background

This study was developed within the framework of the project “Synergy of eHealth and digital skills
in Georgia, Moldova and Ukraine: a way to increase the resilience of the Eastern Partnership civil
society in times of crisis”, which is implemented with the support of the Eastern Partnership Civil
Society Forum and the European Commission.

1.2 Objectives and Tasks

The main objective of the research is to study state of play in Georgia and deliver relevant
recommendations for further developing eHealth direction. The scope of this part of the research
report is the investigation of eHealth in Georgia with an overview of its progress and development
during last years. For this reason, the analysis covers 6 different dimensions:

1. eHealth Legislation and Policy

2. eHealth Governance
3. eHealth Infrastructure and Services
4. Innovation, Research
5. Capacity, Competence, Resources
6. International Cooperation, Projects, Initiatives

1.3 Expected Results

Under this research, 6 main hypotheses has been formed. Hypothesis represents the positive
statement related to each research topic, and assumes the best scenario with all dimensions. This
research will examine all main 6 hypothesis based on information collected from secondary and
primary research methods.

The six hypotheses are the following:

Research topic 1: eHealth Legislation and Policy

Hypothesis 1: There is sufficient legal clarity/certainty in the country regarding eHealth.

There is active eHealth strategy and policy. All sub-sectors of eHealth have determined policy
and regulations. eHealth data protection is regulated.

Research topic 2: eHealth Governance

 Hypothesis 2: Country has established a dedicated government body, specifically working on
eHealth sector regulation and development. All necessary stakeholders for eHealth
governance are on place and their responsibilities are well described.

Research topic 3: eHealth Infrastructure and Services

Hypothesis 3: Country has established Health Information System and relevant

infrastructure, which is interoperable and based on EU standards. EHR, eRx and all the
primary eHealth systems are on place.
Research topic 4: Innovation, Research

Hypothesis 4: Country has policy and effective mechanisms, supporting innovations in

eHealth and development of new eHealth technologies.

Research topic 5: Capacity, Competence, Resources

Hypothesis 5: Country has established mechanisms for increasing eHealth competencies,

including university programs and separate training programs/qualification courses intended
to improve digital skills of citizens in eHealth.

Research topic 6: International Cooperation, Projects, Initiatives

Hypothesis 6: Country has a close cooperation with EU on eHealth related issues, including
negotiations on cross-border health information exchange. There are public and private
platforms, enhancing eHealth sector through the country/region.

2. Research methodology
2.1 Assessment Approach
In order to deliver high quality research outcome, this study examines secondary (desk research), as
well as primary research methods.

All 6 topics will be examined in secondary and primary research phases. Particularly:

- Study of all regulatory legal acts in the electronic health care system of the country;

- Description of the history of the creation of the country's e-health system (indicating the most
important legal acts adopted for reform), as well as plans to improve the system in the future.

- Study of institutions in the e-health system of the country: principles of work (indicating the
defining regulatory legal acts), functions, regulatory legal acts that guide them;
- Description of the features / functions of the software for the operation of the e-health system of the
country;

As a result, several types of obligatory information needs to be generated and submitted as follows:
 
1.1. Table of legal acts regulating the work of the e-health system of the country:

Document Document Acceptance Nam Main aspects of the eHealth

number Type date e systems

         

… … … … …

1.2. Table of institutions in the health care system of the country:

Name of the Basic operating The main functions of an institution Main acts, regulating
institution principles in the e-health system the work

       

… … … …

1.3. Table of national eHealth systems (software), developed and governed by public institutions:

Name of the system Main Brief Stakeholders, governing structure and

(software) (links if available) functions history main acts, regulating the system

       

… … … …

1.4. A visual diagram of the functioning of the national e-health system, indicating institutions,
levels, functions/roles, processes (the movement of financial resources, personnel, users, etc.) and a
description of the features / functions of the system software.
 1.5. Textual description of the information given in paragraphs 1.1 - 1.4, with generalizing
conclusions.
Media Analysis
The second part of the desk research is analysis of national media and official web pages of the
respective authorities and statistical bodies in order to track the evolution of eHealth system: Content
analysis of the national media, official web pages of the authorities, service institutions responsible for
the functioning of the eHealth systems and statistical bodies in order to track the performance of the
eHealth system (sources are selected from the moment the eHealth systems were launched to the
time the study was conducted).

   
2.1.1. Analysis of the official websites of the authorities, service institutions responsible for the
functioning of the national e-health system, and state statistics bodies provides for Gathering
information and entering it into the following table:

Name of Publication Link to Type of publication (choose the appropriate

publication / site title publication one):
- eHealth regulating the work of the eHealth
systems;
- description of the national eHealth systems
(including statistical data)
- explanation of the work of the eHealth for
users and / or technical support
- improvements
- problems

       

… … … …

2.1.2. Textual conclusions made on the basis of the table regarding the official websites of the
authorities and service institutions responsible for the functioning of eHealth systems, state statistics
bodies. The conclusions should determine the ability to provide answers to the following questions
based on the information available in the sources under study:
- "How to use the eHealth systems?"
- "Is contact information, technical support, "hot lines" available?"
- “How is the eHealth systems organized and working?”
- “Is there any statistical information regarding the eHealth systems?”
- “Are there training programs for developing digital skills in eHealth?
 
 2.2.1. An analysis of the media that most intensively covers the work of the national eHealth
systems:
 Name of Publication Link to Type of publication The nature of the
publication / title publication (choose the appropriate publication, where:
site one): "+" - positive attitude
- Laws, regulating the towards the eHealth
work of the eHealth systems;
- description of the "-" - negative attitude
eHealth systems towards the eHealth
(including statistical systems / coverage of
data) problems in the operation
- explanation of the of the system;
work of the eHealth "+/-" - the neutral nature
system for users and / or of the publication
technical support
- improvements
- problems

         

… … … …  

2.2.2. Textual conclusions made on the basis of the table, which provide answers to the questions:
- How intensively is the topic of the national eHealth systems covered in the media?
- Are there sources (other than those mentioned in paragraph 2.1.1.) explaining how to use the
national eHealth systems?
- What problems arose in the work of the systems? Have the problems been fixed at the time of the
study?
- Are there recommendations from specialists/experts regarding the further reform of the eHealth?
Description of the main recommendations.
- Are there training programs for developing digital skills in eHealth?

In-depth online interviews

6 respondents have been interviewed under primary research phase.

Questionnaire has covered all 6 main research topics of the study and all hypothesis has been
evaluated based on answers of the respondents.

Interviews have been recorded and transcripts have been made.

2.2 Respondents and sources
Respondent 1: Ketevan Goginashvili – Head of Health Policy Division at Policy department of
Ministry of Internally Displaced Persons from the Occupied Territories, Labor, Health and Social
Affairs of Georgia.

Respondent 2: Aleksandre Turdziladze – Deputy Director at NCDC

Respondent 3: Representatives of ITA

Respondent 4: Zviad Kirtava - Program Coordinator of One-cycle Educational Program of Medical

Doctor at Caucasus University

Respondent 5: Salome Abashidze – Manager of the clinical process development department at EVEX
medical holding.

Respondent 6: Temur Gaboshvili – Head of IT department at Aversi Clinics

Respondent 7: Irakli Sasania – managing partner at My Doc Teleclinic

3. Research Findings and Recommendations

3.1 eHealth Legislation and Policy

3.1.1 Policy and Strategy

Table 1: eHealth Policy and Strategy documents

Document Document Type Acceptance Name Main aspects of the

number date eHealth systems

904 Law of Georgia 08/06/2001 Law of Georgia on The Law gives definition
Medical Activities of telemedicine. Also
gives broad instructions
how telemedicine tools
should be issued and who
should be involved.

Not Strategy 2011 Strategy of Georgian USAID was largely

Approved Health Management supported creation of
but Information System – health information
Published ‘Healthy Georgia for management system. This
you’ – developed by document determines the
MoIDPOTLHSA, with strategic vision of USAID
help of USAID and the Ministry working
groups. The document
has not been approved.

724 Resolution of the 26/12/2014  On Approval of the This legal act gives short
Government of State Concept of the situation analysis and
Georgia Health Care System of gives priorities for
Georgia for 2014-2020 healthcare development.
"Universal Health Care Developing the health
and Quality information systems are
Management for the mentioned among the
Protection of Patients' priorities.
 Rights"

N/A Parliament of 2017 Vision for the Determines priorities of

Georgia development of the healthcare field. eHealth
healthcare system in field one of 5 priorities.
Georgia by 2030

Not Strategy 2022 National Strategy on Draft version of the

Approved Health Protection 2022- Strategy, developed by
2030 the MoIDPOTLHSA, in
cooperation with EU.
Strategy sets development
of eHealth systems as one
of its priorities.

Georgia currently does not have formally adopted and active national eHealth strategic document.
However, there have been several strategies, regulating eHealth development. First eHealth strategy
have been developed in 2011, with help of USAID. The strategy was comprehensive and was covering
almost all main aspects of digital healthcare development, aiming to create eHealth ecosystem and
establish main principals for future developments. However, the strategy was not specifying
comprehensive action plan for the implementation of the strategy. There were not specified time
frame and responsible persons defined. However, the strategy has not been approved, but it was
published.

Later, in 2014, government of Georgia has approved the state concept of Georgian Healthcare System
2014-2020 "Universal Health Care and Quality Control for the Protection of Patients' Rights" (Decree
N724). The document overviews existing eHealth systems and defines the goals for future definition
of eHealth. Main priorities, the document declares, are development of integrated eHealth systems
and related legislative bases, including transition of patients’ health information from hospital and
other providers, and confidentiality and protection of patients’ data. However, by the end of the
strategic period, strategic goals have been reached only partially.

While there is no unified strategy for eHealth development on national level, there are several
sectoral strategies, containing outcomes and outputs related to the development of particular eHealth
systems. For example, National Strategy for the Promotion of Maternal and Newborn Health of
Georgia for 2017-2030 and the Action Plan for its Implementation for 2017-2019, defines specific
goals on development of Birth Registry. The system contains information on pregnancy, childbirth,
postpartum period, abortion, as well as maternal deaths, stillbirths and early neonatal deaths. The
Strategy aims to develop an effective and customer-oriented health information system that facilitates
data collection, communication, and coordination between different service levels, as well as between
service providers and patients.

Strategy of National Disease Control and Public Health Center, developed in 2013, talks about the
necessity to develop registries for immunization, birth registry, death registry and disease specific
registries. Those registries have been developed under strategic period.

While executive bodies have luck of holistic approach, Parliament of Georgia has published its Vision
for Developing the Healthcare System in Georgia by 2030 (published in 2017). This document
contains 5 main pillars of healthcare:

1. High Quality Medical Service

2. Highly Qualified Medical Personnel
3. Medication, Drugs and Technologies
4. Healthcare Funding System
5. Governance and Electronic Healthcare System

Thus, fifth pillar of the document is dedicated to the development of eHealth systems, related policy
and legislation. The document states that existing healthcare information system is still not
comprehensive in terms of data collection, quality, standardization and evidence generation, and
grasps the necessity to develop the electronic healthcare policy and strategy in a way that this field,
together with the efficient management of the healthcare system, becomes a modern mechanism for
rapid implementation of integrated healthcare and personalized medicine.

This document also talks about the very important components of eHealth, such as telemedicine,
mobile healthcare and distance learning, and emphasize the necessity to implement legislative and
technological changes and to develop an interoperable system harmonized with similar systems in the
European Union.

Overall, the main objective of this section is to develop an efficient system of administration in the
healthcare field and improve the general electronic system of healthcare and develop a general state
multi-sector “Health in all polices” approach.

This document sets target on using electronic medical record systems by the medical institutions.
Also parliament wants 30% of medical specialists be able to use medical applications.

Recently, MoIDPOTLHSA, with help of EU representation in Georgia, has developed draft version of
“National Strategy on Health Protection 2022-2030”. The Strategy, based on evidence-based policy
approach, sets a clear path for the development of the country's healthcare system by 2030 and
identifies the strategic directions required for its implementation. The goals and objectives of this
strategy reflect the government's vision in the field of healthcare and, at the same time, are based on
internationally recognized principles and focus on the priorities of the sector.
The National Health Strategy Paper includes the following key sections:

Situational analysis: Describes the current state of the healthcare system, compares country data with
global and European regional trends.

Strategic Framework: Defines the main strategic directions of the so-called health systems of the
World Health Organization. According to the "building blocks". The National Health Strategy
includes seven key priorities, as the Covid-19 Pandemic includes six blocks in the WHO Health
System that aim to improve public health preparedness and response to emergencies. Indicating
responsible parties and relevant outcome indicators.

The action plan – is written on a quarterly basis and covers a three-year implementation period. It
contains 7 main strategic goals:

 Goal 1: Strengthen governance in the health sector.

 Goal 2: Improve the equity and efficiency of the health financing system.
 Goal 3: Develop human resources in the healthcare sector.
 Goal 4: Ensure access to high quality, effective and safe medicines and medical products.
 Goal 5: Strengthen health management information systems.
 Goal 6 Strengthen and improve the quality of health services.
 Goal 7. Strengthen the public health system to improve preparedness and response to public
health risks

Goal 5 is dedicated to the developing of eHealth systems. Strategy sets the following goals for eHealth
development:

Task 1. Strengthening digital healthcare management.

Task Outcome Indicator 1.1 Share of healthcare providers involved in eHealth reporting system (2020
baseline: 93%; 2030 target: 100%).

 Activity 1.1. Introduce a legislative and methodological framework that aligns sectoral
objectives with IT objectives to ensure the effective use of digital technologies in healthcare.
 Activity 1.2. Development of Information Technology Service Management (ITSM) processes.
 Activity 1.3. Increase the competencies of public servants in terms of digital technologies and
e-health.
 Activity1.4. Introduce analytical electronic tools to evaluate the effectiveness of state health
programs.

Task 2. Strengthen the architecture and services of the e-health system, improve the electronic data
exchange system and quality.
Task Outcome Indicator 2.1. Share of medical facilities with "Patient Summary", electronic medical
records, electronic prescriptions and related to the unified electronic platform (2020 baseline rate
82%; 2030 target rate: 100%).

 Activity 2.1. Improving digital technologies and e-health IT infrastructure.

 Activity 2.2. Strengthening information security.
 Activity 2.3. Improving the electronic data exchange system and quality.
 Activity 2.4. Strengthen supervision and monitoring of irrational drug use and polypharmacy
by improving electronic prescription software.

Task 3. Promoting the introduction of digital health technologies and telemedicine services.

Task Outcome Indicator 5.3.1. Share of rural primary health care centers that use digital e-health
technologies in their daily, routine activities (2020 baseline: 6.5% (50 primary health care centers);
2030 target: 100%).

 Activity 3.1. Promoting the use of telemedicine services.

 Activity 3.2. Expanding the e-health infrastructure needed in medical facilities across the
country.
 Activity 3.3 Increase the capacity and qualifications of medical staff in digital technologies
and e-health.
 Activity 3.4 Use e-health services in emergency management.

There is no dedicated strategy for telemedicine or mobile medicine. However, as it mentioned above,
draft version of “National Strategy on Health Protection” includes tasks on development of
telemedicine. Also, The Ministry supporting a development of those fields by initiating new
telemedicine projects and mobile health applications.

Interoperability is the key for harmonizing the systems within the country and with EU. However,
there is no active dedicated strategy for interoperability or cross border interoperability of eHealth
systems, which would give the direction and would dictate standards for eHealth systems within the
country.

The first eHealth strategy in 2011 contains separate sections on using international standards for
obtaining, saving, transferring and receiving health data. Those standards are HL7 and DICOM,
which are widely used on international level. Later, the Ministry has introduced new EHR system,
which is also based on HL7 and DICOM standards. Thus, there is no formal strategy, establishing
interoperability standards, but the Ministry itself is oriented to use them.
Hypothesis 1: There is sufficient legal clarity/certainty in the country regarding eHealth. There is
active eHealth strategy and policy. All sub-sectors of eHealth have determined policy and regulations.
eHealth data protection is regulated.

Main Findings:
Under this study, there has not been found any active eHealth strategy. Recently, the National Health
Strategy is being developing, which also names health information management systems one of its
priorities. However, there is no separate strategy, dedicated to eHealth development on national
level.

Recommendations:
 The Ministry should prepare and approve the national strategy of eHealth, which will
become a fundament for eHealth development. The strategy should establish eHealth
concept, and set main priorities of the field. The document should define general framework
of the field, should be holistic and cover all main aspects, including analysis of the current
state of eHealth systems and governance, interest of main stakeholders and international
experience.
 The Ministry also should prepare and approve an action plan for implementation of the
strategy.

3.1.2 Regulation of eHealth field

Table 2: Main legal acts, regulating eHealth systems

Document Document Acceptance Name Main aspects of the eHealth

number Type date systems

283 Law of 05/05/2000 Law of Georgia on patient Defines patient’s right to

Georgia rights access their health
information. Also
introduces the necessity of
patients’ consent.

01-55/ნ Order of the 25/11/2011 On approval of the rule of This order declares that
Minister of production of dental medical documentation can
 Georgia medical documentation be produced electronically.
Also order says that recipes
should be prescribed
electronically.

5669-რს Law of 28/12/2011 Law of Georgia on Defines general approach

Georgia Personal Data Protection towards personal data
protection and processing.

6391-Iს Law of 05/06/2012 Georgian Law on Defines general rules for

Georgia Information Security information security,
including personal
information and medical
data.

01-41/ნ Order of the 01/01/2012 On approval of the rule of This order declares that
Minister of production of outpatient medical documentation can
Georgia medical documentation be produced electronically.
Also order says that recipes
should be prescribed
electronically.

108 Order of the 01/01/2012 On approval of the rule of This order declares that
Minister of production of in-patient after discharge, recipes
Georgia medical documentation should be prescribed
electronically.

36 Resolution 21/02/2013 On the measures to be Indicates the main modules,

of the taken in the transition to which are necessary to
Government universal health care register cases under UNC.
of Georgia Describes its main functions
and determines obligations
for UNC providers.
Resolution obliges providers
to use Case registration
module, eReporting
module, ePrescription
system, Registry of C
hepatitis, Immunization
module,
01-29/ნ Order of the 26/07/2016 Approval of the electronic Establishes the electronic
Minister of circulation of form N3 prescription (ePrescription)
Georgia prescription of system. Determines the
pharmaceutical product management, users and
(medicinal product) other stakeholders.
belonging to the second Determines the obligations
group of healthcare providers to
the system. Determines its
main functionalities.

01-37/ნ Order of the 24/08/2016 On approval of the rules of Establishes birth-death

Minister of birth and death medical registry. Determines its
Georgia certificate forms, their functionality and rules of
filling and sending, the filling it. Determines
rule of issuing birth and obligations on sending the
death information from relevant information.
the electronic database of
the LEPL - State Services
Development Agency

459 Resolution 06/10/2017 Georgian National Emphasizes a necessity of

of the Strategy for Promoting EHR implementation,
Government Maternal and Newborn which would enable
of Georgia Health 2017-2030 and its coordinated care and
Action Plan for 2017-2019 increase quality of care.

01-1/ნ Order of the 15/01/2019 Determining the Establishes the EHR system.
Minister of functioning and operating Determines the EHR
Georgia rules of the Electronic management, users and
Health Record System other stakeholders.
(EHR) Determines the obligations
of healthcare providers to
send patient’s health
information to EHR system.
Determines the main
functionalities of HER.

01-26/ნ Order of the 25/03/2019 On the production and Determines an annual

Minister of delivery of medical electronic forms of
 Georgia statistical information departmental statistical
reporting to be submitted
by medical (including
scientific-research)
institutions and deadlines
for submission

01-11/ნ Order of the 03/02/2021 On Approval of the Rule Determines the COVID-19
Minister of for the Introduction and vaccination procedures.
Georgia Immunization This order obliges providers
Management of the to maintain sufficient level
COVID-19 Vaccine of IT infrastructure and to
use immunization registry

4 Resolution 12/01/2022 Approval of 2022 state Obliges health providers to

of the health programs use ePrescription system.
Government Obliges UHC providers to
of Georgia use cancer registry,
immunization registry,
COVID-19 immunization
registry, Hepatitis C and B
registry, Blood donor
registry, Registry of
Tuberculosis, Birth
Registry, Electronic
program of the Pregnancy
and Newborn Surveillance,

eHealth field has multiple dimensions, and all those dimensions requires to be regulated. In Georgia
there is no universal act, regulation national eHealth framework and infrastructure. Regulatory
environment consists with different legal acts, regulation different aspects of eHealth. The main
aspects of the field are:
 General legislative bases;
 Regulation of separate eHealth systems;
 Regulations of mHealth, telemedicine;
 Legal certainty of domestic and cross-border interoperability;
 Regulation of healthcare data privacy protection;
 Patient's control over privacy protection.
General legislative bases in Georgia includes several regulations. The most important is the
Resolution of the Government of Georgia on the measures to be taken in the transition to universal
health care. This resolution has been approved in 2013 and indicates the systems, which should be
used in order to be able to provide medical services under National Universal Health Coverage (UNC)
schemes. This legal act lists the main modules, which are necessary to register cases under UNC,
describes its main functions and determines obligations for UNC providers. Resolution also obliges
health service providers to use Case Registration module, eReporting module, ePrescription system,
Registry of C hepatitis, Immunization module, etc.
Another general regulations are the Order of the Minister of Georgia on approval of the rule of
production of outpatient medical documentation, approved in 2012, the Order of the Minister of
Georgia on approval of the rule of production of inpatient medical documentation, also approved in
2012 and the Order of the Minister of Georgia on approval of the rule of production of dental medical
documentation, approved in 2011. Those orders declares that all types of medical documentation can
be produced electronically. Also, all those orders says that recipes should be prescribed electronically.

Resolution of the Government of Georgia on Approval of 2022 state health programs obliges health
providers to use ePrescription system. Also, it obliges UHC providers to use cancer registry,
immunization registry, COVID-19 immunization registry, Hepatitis C and B registry, Blood donor
registry, Registry of Tuberculosis, Birth Registry, Electronic program of the Pregnancy and Newborn
Surveillance etc.

Most of the regulatory acts in eHealth field are relating to the particular eHealth systems. The
Resolution of the Government of Georgia on the measures to be taken in the transition to universal
health care is the first regulatory document, mentions HIMS systems. This law, as it is mentioned
above, describes the basic functionalities of several HIMS systems. Under this law, usage some of the
HIMS systems are mandatory for UNC providers. Also it describes instructions of use of the systems,
deadlines and responsibilities of different users.

Order of the Minister of Georgia on approval of the rules of birth and death medical certificate forms,
their filling and sending, the rule of issuing birth and death information from the electronic database
of the LEPL - State Services Development Agency has been approved in 2016. This order establishes
birth-death registry and determines its functionality, instructions, and responsibilities.

In 2016, when state ePrescription systems has been developed, the ministry created order on
aapproval of the electronic circulation of form N3 prescription of pharmaceutical product (medicinal
product) belonging to the second group. Establishes the electronic prescription (ePrescription)
system. Determines the management, users and other stakeholders. Determines the obligations of
healthcare providers to the system. Determines its main functionalities.
Later, ministry developed HER system and has published its regulatory act, an order determining the
functioning and operating rules of the Electronic Health Record System (EHR). This order establishes
the EHR system. Determines the EHR management, users and other stakeholders. Determines the
obligations of healthcare providers to send patient’s health information to EHR system, etc.

In 2019, the ministry has published new order on the production and delivery of medical statistical
information, which determines an annual electronic forms of departmental statistical reporting to be
submitted by medical (including scientific-research) institutions.

Also there are a few order, relating the procedures of COVID management and immunization.

Regulations of mHealth and telemedicine

There is no separate legislation on mHealth. However, in the Law on Medical Activities, government
introduced the concept of telemedicine. There is the definition of telemedicine in the law. Under the
the law, doctors have got the right to make online consultations using special telemedicine tools. Law
also includes rules on confidentiality while consulting online.

Regulation of healthcare data privacy protection and Patient's control over their health data

Protection of patient’s health related data, as well as protection of personal data is guaranteed by Law
of the Republic of Georgia on Personal Data Protection and by the Law of the Republic of Georgia on
Information Security.
Law of Georgia on Personal Data Protection defines general approach towards personal data
protection and processing. According to the law, data processing is any action taken against personal
data: collection, recording, storage, use, disclosure, photo printing, transfer to a third party,
distribution, deletion, destruction and more. The law sets out the rules, principles, grounds and
security measures that a data processor must follow when processing personal data: an existence of a
legal basis and the observance of the principles established by law. Data processing is allowed if:
A) There is the consent of the data subject - the voluntary, informed and explicit consent of the
person to the processing of his personal data.
B) data processing is provided by law;
C) data processing is required for the data processor to perform the duties assigned to it by law - for
example, to store data for tax purposes for a certain period of time;
D) data processing is necessary to protect the vital interests of the data subject - for example, if a
person's life is in danger during an emergency and it is necessary to determine the location to save it;
E) data processing is necessary to protect the legitimate interests of the data processor or a third party,
unless there is an overriding interest in protecting the rights and freedoms of the data subject;
F) by law, the data are publicly available or made available by the data subjec
G) data processing is necessary to protect the public interest important in accordance with the law -
for example, crime prevention, protection of property or minors from harmful influences;
H) Data processing is necessary to review the application of the data subject or to provide services to
him.

Among the the personal data, the law defines the special type of data, which among others include
person’s health information. When it comes to the processing of special categories of data, the law
sets a higher standard and sets different grounds for their processing. The law says that processing of
the special category data is forbidden, unless there is the written consent of the data subject or in
cases where:
A) processing of data related to conviction and health status is necessary to make a decision on
employment based on the nature of the employment obligations and the relationship;
B) data processing is necessary to protect the vital interests of the data subject or a third party
and the data subject is not physically or legally capable of consenting to the processing of the
data;
C) the data are processed by the public health care, health care or the institution (worker) for
the protection of the health of the natural person, as well as if it is necessary for the
management or operation of the health care system;
D) the data subject has made public the data about him / her without explicitly prohibiting their
use;
E) The data are processed by a political, philosophical, religious or professional association or
non-profit organization in the course of its legitimate activities. In such a case, the data
processing may be related only to the members or persons of that association / organization
who have a permanent connection with that association / organization;
F) Data is processed in order to maintain the personal files and registers of the accused /
convicts, their individual planning of the sentence and / or parole of the convict and the
change of the unserved part of the sentence to a lighter sentence;
G) the data are processed for the purpose of enforcing the legal acts provided for in Article 2 of
the Law of Georgia on Crime Prevention, Execution of Non-custodial Sentences and
Probation;
H) G1) data are processed to coordinate the re-socialization and rehabilitation of convicts and ex-
prisoners, the implementation of crime prevention measures and the juvenile referral process;
I) the data are processed in cases directly provided for by the Law of Georgia on International
Protection;
J) data is processed for the operation of a unified migration data analysis system;
 K) data are processed for the purpose of exercising the right to education of persons with special
educational needs;
L) The data are processed for the purpose of discussing the issue provided for in paragraph 2 of
Article 11 of the Law of Georgia on Prevention of Violence against Women and / or Domestic
Violence, Protection and Assistance to Victims of Violence.

The Law of Georgia on Information Security aims to facilitate the effective and efficient
implementation of information security, to establish the rights and responsibilities of the public and
private sectors in the field of information security, as well as to establish mechanisms for state control
over the implementation of information security policy. The law introduces the concept of critical
information system, which means information systems, the continuous functioning of which is
important for the defense and / or economic security of the country, for the normal functioning of
state government and / or society.
According to the law, the Ministry and its subdivisions represents the subject of the first category of
critical information systems.
According to the law, the subject of the critical information system is obliged to adopt the rules of
internal use of information security, which serve to enforce the provisions of this law and determine
the information security policy of the organization. Also, an information security policy must meet
the minimum information security requirements. Minimum information security requirements are
set by the order of the Head of the Operational-Technical Agency, taking into account the standards
and requirements of International Organization for Standardization (ISO), the US National Institute
of Standards and Technology (NIST) and the Information Systems Audit and Control Association
(ISACA).

The Law of Georgia on patient rights defines patient’s right to access their health information. The
law says that the patient has the right to access the medical records and request an amendment to the
existing patient information. At the same time, the patient has the right to request a copy of any part
of the medical records.

The law ensures the protection and inviolability of the privacy of the patient. It says that the health
care provider is obliged to protect the confidentiality of the information available to him / her both
during the patient's life and after his / her death. Disclosure of confidential information by a
healthcare provider is permitted if:

A) the patient's consent is obtained;

B) non-disclosure of information endangers the life and / or health of a third party (whose
identity is known);
C) when using patient information for educational or scientific purposes, the data is presented in
such a way that it is impossible to identify the person;
 C 1) The information refers to the fact of violence against women and / or domestic violence and
there is a danger of recurrence of violence. This information is provided only to the relevant state
body to protect the patient's rights and interests;

D) Is defined by the legislation of Georgia.

Main findings:

Georgia doesn’t have comprehensive legislative acts, which would create overall framework for
eHealth development. Regulatory part of the field is fragmented and mainly contains separate
regulatory acts on particular eHealth systems.

Recommendations:

eHealth is multi-dimensional field, involving multiple stakeholders, systems and data. Complexity of
the field also requires complex and holistic regulatory system, which needs to be created with
cooperation of multiple stakeholders and institutions. Comprehensive regulation is one of the
fundament for developing the field.

3.2 eHealth Governance

Table 3. Main stakeholders of eHealth field

Name of the Basic operating The main functions of an Main acts, regulating
institution principles institution in the e-health the work
system

Ministry of Government  Main policy maker, 1. Resolution of the

Internally institution. Main policy responsible to create Government of
Displaced Persons maker in healthcare, policy and strategy Georgia #473 On
from the Occupied social affairs, labor relating eHealth and Approval of the
Territories of fields and IDP related ensure its’ enforcement. Statute of the
Georgia, Labor, issues. In most of the cases Ministry of Internally
Health and Social initiatives creation of Displaced Persons
Affairs  major eHealth systems, from the Occupied
legislative basis and often Territories, Labor,
plays major role in their Health and Social
 implementation. Affairs of Georgia

2. Order of the
Minister of Georgia
#01-22/ნ
Regulations of the
Structural Units of the
Ministry of Internally
Displaced Persons
from the Occupied
Territories, Labor,
Health and Social
Affairs of Georgia 

LEPL - Information LEPL under the Responsible for the Order of the Minister
Technology Agency Ministry. Responsible development of projects of Georgia 01-48/ნ On
to manage information relating information Approval of the
systems and systems and technological Statute of the Legal
information technology solutions, necessary for Entity of Public Law -
infrastructure of the the Ministry and its Information
Ministry and all LEPL’s LEPL’s. Implementation Technology Agency
under its control. of the full cycle - analysis
of business processes,
Introduction of modern software development,
information testing, implementation,
technologies and support, improvement;
systems.
Creating an integrated Responsible to create and
server and network manage server and
infrastructure. network infrastructure
for the Ministry and its
LEPL’s.

Ensure cyber and

information security of all
its systems and data.

LEPL – National Responsible to manage Agency Eligible to use Order of the Minister
Health Agency country’s healthcare information and health of Georgia #01-91/ნ
 programs information systems of On Approval of the
any units of the ministry Statute of the Legal
Entity of Public Law
- National Health

LEPL - L. A) protection and Manages number of Order of the Minister

Sakvarelidze improvement of the eHealth modules and of Georgia #107/ნ On
National Center for population's health; registries; Processes all the approval of the
Disease Control and B) Ensuring a favorable relevant data. statute of the
Public Health epidemiological L.Sakvarelidze
situation and biological National Center for
safety in the country in Disease Control and
the field of public Public Health
health and biological
safety in accordance
with the state policy;
C) Conducting applied
and fundamental
biomedical and
biotechnological
scientific research in
the field of
microbiology,
immunology and
epidemiology on the
principle of "unified
health" and developing
scientific potential;
D) Implementation of
scientific-research
function, receiving and
issuing scientific grants,
in accordance with the
current legislation.

LEPL - Social The goals of the agency Manages number of Order of the Minister
Service Agency; are to implement the eHealth modules and of Georgia # 01-14/ნ
state policy in the field registries; Processes all On approval of the
of social protection of statute of the legal
 the population and to relevant data. entity of public law -
promote its the Social Service
implementation. Agency

LEPL - Agency for Exercises state control Manages number of Order of the Minister
Regulation of in the field of medicine, eHealth modules and of Georgia #01-64/ნ
Medical and medical activities, registries; Processes all On Establishment of
Pharmaceutical medical-social relevant data. the LEPL - Agency
Activities expertise, educational for Regulation of
activities, medicine and Medical and
pharmaceutical Pharmaceutical
activities. Activities and
Approval of its Statute

Non-profit (non- Functioning as medical One of the goal of SMH is Statute of a non-profit
commercial) legal holding, responsible to to develop telemedicine (non-commercial)
entity - State deliver medical services direction legal entity of a state
Medical Holding from state owned medical holding
medical facilities.

Ministry of Justice Main law maker in the Ministry and its LEPLs Resolution of the
and its LEPLs country. Responsible are responsible to manage government #389 On
for legislative activity citizens’’ personal data. Approval of the
and legal examination Statute of the
of draft normative acts Ministry of Justice of
etc. Georgia

Healthcare Responsible to provide Main users of national

Providers and medical services eHealth systems,
networks - modules, registries
Hospitals,
ambulatories,
independent
medical practices,
dental practices.
Their networks and
associations

Pharmaceutical Executing Using certain systems,

companies. Their pharmaceutical made but the Ministry
 networks and activities and its LEPLs. Pharma
associations companies are obliged to
use ePrescription system.

Vendors – private Domestic and/or Vendors are developing

companies, international different types of eHealth
developing eHealth companies, developing systems mostly for private
systems the variety of eHealth medical and
systems pharmaceutical facilities.
Thus they have influence
on the quality and
functionality of eHealth
systems from hospital and
pharma side.

Donor International Facilitating development

organizations: organizations of eHealth policy,
WHO, EU, Caritas, strategy, regulations and
USA CDC, USAID, systems themselves.
UNDP, UNICEF

… … … …

Diagram 1. Main stakeholders of eHealth in Georgia.

Ministry of Internally Displaced Persons from the Occupied Ministry of Justice and
Territories of Georgia, Labor, Health and Social Affairs of Georgia its LEPLs

LEPL - Information LEPL – National Health

Technology Agency Healthcare Providers
Agency

LEPL - L. Sakvarelidze LEPL - Agency for Regulation

Pharma companies
National Center for Disease of Medical and Pharmaceutical
Control and Public Health Activities

Vendors
LEPL - Social Service
Agency

Donor Organizations
 Non-profit (non-commercial) legal entity - State Medical
Holding
The Ministry of Internally Displaced Persons from the Occupied Territories of Georgia, Labor, Health
and Social Affairs and its LEPLs represents the main stakeholder of national eHealth systems.

The Ministry is main policy maker in healthcare, social affairs, labor fields and IDP related issues.
This institution is responsible to create policy and strategy relating eHealth and ensure their
enforcement. Inside the Ministry, the department of policy, with its sub-units, is responsible for
policy making and strategic planning.

The Resolution of the Government of Georgia #473 On Approval of the Statute of the Ministry says
that the department of policy is responsible to develop / improve regulatory mechanisms and tools to
ensure the functioning of health information systems.

Historically, the Ministry was responsible for developing relevant legislative acts, normative orders
and / or government resolutions. The Ministry has legal department, which focuses on lawmaking
activities. When necessary legal department, in cooperation with healthcare policy department and
under involvement of all relevant stakeholders, leads the lawmaking process.

In most of the cases the Ministry itself initiates ideas for the development of major eHealth systems
and often plays major role in their implementation. For example, in 2016, the Information
Technology Department within the Ministry itself developed and implemented electronic
prescription system. In 2017-2018, this department has developed and implemented EHR system.

The major reforms in the Ministry, which has directly affecting eHealth field, has took place since
May 2021, when the Ministry has abolished the IT department. Before that time IT departments have
been functioning not only in the Ministry, but in many LEPLs of the Ministry, including LEPL - L.
Sakvarelidze National Center for Disease Control and Public Health and LEPL - Social Service
Agency. Under the reform, IT departments has been abolished in the Ministry and in all its LEPLs
and separate entity – LEPL – Information Technology Agency has been created.

LEPL – Information Technology Agency has broad mandate and functions, including:

A) Facilitate the achievement of the goals and objectives of the Ministry and its LEPLs by
introducing developing and maintaining modern information technologies and systems;
B) Management of information systems and information technology infrastructure required for
the functioning of the Ministry's system, as well as personal, social, economic and health data
related to the person from the LEPL - Public Service Development Agency, a legal entity
under the Ministry of Justice of Georgia; Receipt / processing from other government
agencies / institutions. The Agency is obliged to ensure the lawful protection, use / access of
the received information for the protection and management of IDPs, labor and social issues,
 as well as for the management and sustainability of the health care system (including e-
health) by the persons involved in the system;
C) Creation of integrated server and network infrastructure necessary for the effective
functioning and development of the Ministry and legal entities of public law, ensuring its
reliable and efficient operation and development;
D) Ensuring sustainable operation of computer equipment and peripherals, telecommunication
infrastructure of the Ministry and its LEPLs;
E) Ensuring information security of information systems and information technology
infrastructure of the Ministry and its LEPLs;
F) Development, implementation, support and development of integrated information
management systems for the services of the Ministry and its LEPLs;
G) Integration of information systems of the Ministry and its LEPLs in the e-government
systems of the country.

Thus, LEPL – Information Technology Agency, is fully responsible to manage information systems
and information technology infrastructure of the Ministry and all its LEPL’s.

All other LEPLS - National Health Agency, L.Sakvarelidze National Center for Disease Control and
Public Health, Social Service Agency, Agency for Regulation of Medical and Pharmaceutical
Activities – are using different systems in the process of exercising their functions. Before May 2021,
almost all LEPLs had separate IT departments and was developing their own eHealth systems
separately and without coordination.

Non-profit (non-commercial) legal entity - State Medical Holding is responsible to deliver medical
services from state owned medical facilities. This organization is managing the largest state owned
hospitals, ambulatories and primary healthcare practices. Along with its’ main functions, Holding
aims to develop telemedicine field.

Ministry of Justice and its LEPLs – Data Exchange Agency and Service Development Agency - are
important stakeholders for eHealth systems. Almost all eHealth systems are using citizens’ personal
information, data from civil registry and digital signature/stump.

Healthcare Providers and their networks - Hospitals, ambulatories, independent medical practices,
dental practices. Their networks and associations – are main users of national eHealth systems.
Almost all systems, modules, registries are designed to be used by the providers. They are the main
information source for existing national eHealth system.

Pharmaceutical companies, their networks and associations are also involved in national eHealth
system: ePrescription system, developed by the Ministry in 2016, involved pharma side in the
process. When medical system provider prescribes the pharma products, those prescriptions can be
retrieved by pharmacist, after correctly identifying the patients’ personal data.
Vendors, represented as domestic and/or international companies, are developing variety of eHealth
systems for private medical and pharmaceutical facilities. Most of the hospital and ambulatory sector
are using electronic medical record systems (EMR), developed by the private eHealth system
developers. The same applies to pharma sector. Since there is no particular regulation, related to
content and standards for EMR and other eHealth systems, its’ vendors solely, who are making
decision on considering particular standards, while developing the systems. Moreover, vendors are
responsible to integrate their systems with government systems for the purpose of information
transition. Thus, currently vendors have high influence on the quality and functionality of eHealth
systems as well as on integration level with national eHealth systems.

Health sector traditional attracts an attention of international donor organizations. Since starting the
pandemic, at the beginning 2020, eHealth direction became one of the priorities for donors.
Organizations, such as WHO, EU, Caritas, USA CDC, USAID, UNDP, UNICEF etc. are facilitating
various eHealth projects, including development of eHealth policy, strategy, regulations and systems
themselves.

Hypothesis 2: Country has established a dedicated government body, specifically working on eHealth
sector regulation and development. All necessary stakeholders for eHealth governance are on place
and their responsibilities are well described.

Main findings:

The structure of the Ministry has change rapidly during last year. Dedicated agency (ITA) for IT
development has been formed, which also should include eHealth management. However, for now,
ITA does not intervene in eHealth management or development. They state that the only function
they have is maintaining the technical part of the systems. All other functions are disseminated
between LEPLS and the Ministry itself. Thus there is no single structure in the country, which would
be responsible for initiating, developing and implementing the eHealth strategy, action plan and
systems themselves. The users of the systems are mainly LEPLS, while policy is developing but the
Ministry and systems are technically developed and maintained by ITA. This very complex
relationship creates barriers and risks of delaying every process relating eHealth systems.

Recommendations:

It is necessary to establish a National e-Health Agency, the main function of which is to manage and
lead the National e-Health Project, as well as ensure developing of national eHealth strategy and
action plan.
3.3 eHealth Infrastructure and Services

Table 4: Description of HIMS systems

Name of the Main functions Brief Stakeholders,

system history governing
(software) structure and
(links if main acts,
available) regulating
the system

Administration and financial management of health care programs

Case Collect data from medical facilities about healthcare    

Registration program beneficiaries 
Module 

E-Reporting This module is designed by providers to submit both

Module financial and statistical reports of medical services. It
contains information about the services actually
offered. The financial statements refer only to the
services for which the state compensation is expected.
The system applies to other modules to fill in the
preliminary (or uniform) forms of services: Case
Registration, Prescription, Beneficiary registration
module, Dialysis, Autism, etc. The module allows the
employee of the Ministry to review the financial
statements, according to them to formulate the
summary protocols of the work performed on each
provider and submit them to the Finance on the
specified date. Also, in case of refusal to pay the account
in part or in full in the Finance module, the relevant
protocol can be returned to the E-Reporting module for
correction.

Financial Contains information about the costs of the

management intervention and reimbursment by the government.
module for
healthcare
programs

Beneficiary Use to admit patients to medical facilities; Consists of

registration subcomponents such as Psychiatric, Diabetes, etc.
module –
general
ambulatory,
rural doctor,
dialysis,
Psychiatric

Pregnancy and
Newborn
Monitoring
Module

Universal
Healthcare –
Planned
Ambulatory
Module

(Universal This module allows SSA Service center staff to be

Healthcare) reimbursed by the state for their medical service claim.
Referrals The system makes it possible to process the request,
Module make a decision according to it and open a service tax
guarantee sheet. Medications are registered directly in
the E-Prescription module.

(Tbilisi City Is a similar module to the Referrals Module, but is

Hall) Referrals intended for Tbilisi City Hall staff to pay medical
Module services to citizens living in Tbilisi (according to them,
compensation is likely to be at the expense of the city
and not the state). The registration system is also
suggested by the decision of each case commission.
With this module it is possible to provide information
not only about medical services, but also about
medicines. The system transmits medication
 information to the E-Prescription system.

(Adjara) This module is a similar module to the Referrals

Referrals Module, but is designed to apply for medical service
Module fees by Adjara MES staff in Adjara. Performance
Program Financing Module System to pay for services.
The module, which receives information about the
work done from e-Reporting, checks tax capabilities,
enables the registration of such protocols and calls for
the necessary services of the treasury system to transfer
information for the purpose of making payments. The
module represents the first place to enter information:
health care providers, national health programs, service
contracts with providers (indicating the values to be
reimbursed by the state). The module also stores all
possible service trees (financial units) with information
on those who can provide these services in this or that
medical case, the limitations being made by the
patients. It offers information on the financial
statements calculation charter to other modules. The
module receives part of the information about the cost
of the service from the Information Portal module, the
rest of the information is entered manually. Provides
information to USER MANAGENENT about providers.

Autism
reporting and
management
module (City
hall)

Orthopedy(City
hall)

Home care
(City hall)

Social Programs
Hepatitis C
screening
program

Hepatitis C
treatment

Hepatitis C
Analytics

Decisions of
referral
commission for
providers

Referrals
administration
module - for
organizations

E-Reporting
module – for
city hall,
Adjara, NCDC

Reporting on
program
medications

Cochlear
implant -
rehabilitation

Substance The module is intended for the registration of drug

Addiction addicts who receive medication through state programs.
Program A calendar is produced in the module, which records
module when a patient should come to a medical facility and
when medication should be dispensed.

Dialysis module The module is designed for the registration of patients

who undergo a systematic dialysis procedure. It records
 the fact that the dialysis procedure was performed by a
medical institution (both planned and urgent). The data
of this module are used for pre-filling of financial forms
in the E - Reporting system

Regulation of medical activities

Healthcare The main purpose of the module is to register

Facilities information about providers (name, type, addresses,
Licensing / information about the head of the institution and its
Permitting branches), their applications for authorization
Module documents and the documents themselves (indicating
the field of service, document number and date). Facts
of changing and issuing copies of all these documents
are also recorded.

Medical Staff The module contains information about the medical

Certification / staff working in Georgia. Provides information about
Accreditation their education (including diploma number and type),
Module their certificates (including numbers, validity,
specialty).

Auxiliary Modules

The Medical Stores and submits interfaces for searching and editing
Classifications commonly accepted directories: Standardization of
laboratory studies ICD10, NCSP, ICPC-2.

The Log Data Module collects and stores all user requests from all
Base other subsystems. Collected information includes: date,
time, user, URLs. The information is used to track the
problematic situations that occur to users. The storage
time of logs depends on the module

Analytic Tools Module allows user to perform analytics based on a

database (graphical representation of data and grouping
in different sections). The system is processed but not
used.

Analytic Data This is a database in which data is transferred daily

Base from different systems and transformed into a
convenient unified structural table (Data Warehouse).

User The module is responsible for a single user point for all
Management modules of HMIS USAID systems. The system is
Module designed so that if a user logs into one of HMIS USAID
modules, they will log in to the following modules
during the session without re-entering their password
and login. The system supports implementations of
different types of users.

Limits data Base The main purpose is to set limits and keep financial
balances for each patient. The module uses HTML pages
to view and update data, which can be embedded in
other modules (namely, built into the Referral Module).
The balances support the patient's funds blocking /
unlock functionality as well as write off / return funds
from patients’ accounts. The module uses data from
Common Data, the Healthcare program
Financing Module (limit calculation to get the rules) for
its work. Or agreed on a guarantee amount). The
module also plans to add a function for sending emails.

Socially
vulnerable
population

Immunization and stock management

Immunization / Module designed to provide information about

Vaccination vaccines, to whom and when have they been
Module administered. Reasons for writing them off at a
particular medical facility. Detailed information on
vaccines should be provided with reference to the
specific packaging serial number. Information on
vaccines is available to the specific medical facility that
receives the information from Stock Management
Module.

Immunization
Mobile
Application

Stock The module is in no way related to the bill and its data
Management is not uploaded anywhere. Stock Management Module -
Module Designed for all NCDC product descriptions and
movements. For example, vaccines. Initial information
on all vaccine batches destined for circulation in the
country will be provided by the NCDC. After entering
the information, the parties distribute the vaccines to
the branches (regions and centers), then the employees
of the centers distribute the vaccines to the medical
service providers.

Monitoring and management of infectious diseases

TB Module Intended for the registration of information on TB

patients. According to the patients, a schedule of several
months is set for the dispensing of medicines. Fixation
of patients coming, their references to laboratory tests
and the results of these tests. Based on this data, a
report is formed in e-reporting is. To provide further
financial assistance to patients who undergo regular
check-ups at the MIA. In this case the providers receive
this money from the NCDC, hence the reports on the
work performed will not be transferred.

HIV prevention
module

Information sources

Information The most common use of this module is simply a site

Portal with information accessible to the citizen. On the other
hand, medical service providers have the opportunity to
correct information about their facilities, including a
list of services offered and prices. Pharmacists can
provide information on the prices of medicines here.
Pricing information is further used by the health care
program FinanncingModule.
 http://cloud.moh.gov.ge/Default.aspx?languagePair=en-
US

Emergency
Portal

Hospital
regionalization
plan

Pharmaceutical Activity

Pharmaceutical It provides the opportunity to enter information about

Products medications, their registration, change of registration
Module data and the essence of the change. Used in both
business and customs importation of medicines.

E-Prescription Is designed for physicians to enter prescriptions. By SSA

Module (for the Service Center staff (for the treatment of oncological
medications diseases) and entering this information about the sale of
under certain medicines through the pharmacy by the pharmacy staff.
state programs) Prescriptions introduced by this system suggest a partial
reimbursement of the cost of medicines by the state.
When entering a patient's prescription, pharmacy staff
indicate the warranty number and a portion of the cost
of the medication will be written off. Data on the sale
of medicines with state guarantees are transferred to
the E-Reporting system for pre-filling of financial
forms. He is in the process of resolving organizational
moments to agree on a task with the Ministry of Justice,
which currently maintains the relevant registries.

Medication
administration
module (City
hall)

Pharma module

Useful links
Day Center
Management
Module

Crisis feed
vouchers

Professional
training module

Module for
doctors and
nurses
employed in a
mountainous
settlement

Chronic Disease
Medication
Portal

Birth Death
Registration
Module

Birth Registry

Birth registry
Analytics

EIDSS –
electronic
Integrated
disease
surveillance
system
 Logistic Module

Blood Bank

Medical
Statistics

LIMS

Chemical
Registry

Financial
Module

Corona Lab

Table 5. eHealth systems, developed separately from HIMS

Name of the system Main functions Brief history Stakeholders,

(software) (links if governing
available) structure and
main acts,
regulating
the system

EMC: Capabilities:
EHR and The EHR module is intended for the
Doctor/Hospital registration and storage of clinical
Portal and Mobile information as well as for the provision of
Application (Non- medical services. The financial
Functional) information and financial management
provided by HIMS remains within the
scope of HIMS.
Information is stored in the EHR module
repository both manually and through the
 Doctor / Hospital Portal module web form
module, as well as through the existing
HIS clinic WEB service.
Doctor / Hospital Portal and Mobile
Application - The modules give us access
to clinical, reference and financial
information for doctors, staff of the
Ministry and citizens of Georgia, in
accordance with the web portal and
mobile application. This module also
allows you to record the facts of planned
and unplanned medical services, cases of
patients' visits to polyclinics,
accommodation, services as provided by
the state guarantees and planned cases,
which were paid from other sources.
The EHR, Doctor / Hospital Portal and
EmC modules were put into pilot
operation, but were not introduced.

New EHR system The EHR system is a digital repository of

(Functional) data on a patient's state of health.
The purpose of the EHR system is to
collect, store, share, and process electronic
records of patient health status from
authorized persons, and thus facilitate the
development of a continuous, effective,
patient-centered, and quality, integrated
health care system.
The EHR system includes information
collected by an independent medical
practitioner (hereinafter referred to as a
physician) during any hospitalization
episode or outpatient visit.
HER System has Doctors’ Page, Patients’
Page and Analytical Page.

State Electronic Electronic recipe involves electronic

Prescription System information through bilateral exchanges
 between the doctor and the pharma, either
directly or through an intermediate
network.

Patient Portal The purpose of the patient's portal is to

increase the degree of awareness of the
citizens about their health related data, in
order to ensure more informative
involvement of the patient in the
treatment process, to make the processes
of personal data processing more
transparent.

The patient portal provides important

information such as patients’ medical
records, electronic prescriptions
(prescriptions), information about the
realization of prescriptions in the
pharmaceutical network. The same page
allows the patient to get information about
the processing of their personal data.

“I Quit” – Tobacco
control

STOPCOV After downloading the app, user will be Since the April
given a unique ID, which allows her to 2020, after
completely anonymously identify social COVID -19 has
contacts between users of the app. Cases of begun to
contact of a certain duration and distance, spread,
in encrypted form, are stored locally in the Ministry started
memory of both users' smartphones. If any adopting special
person is confirmed to have COVID-19, mobile
those who have been in contact with the application –
confirmed case in the last few days will STOPCOV. The
receive a warning, instruction - to stay in app is
self-isolation and contact the authorities developed in
immediately. Austria and has
 been
successfully
used in many
western
countries, as
well as in
Australia and
Japan.
Downloads are
available from
the App Store
and Google
Play, and it’s
completely
free.

booking.moh.gov.ge The main function of the app is to provide

booking places for Covid vaccination. The
system includes all vaccine providers and
gives information about free sites for
particular day. The citizen has the
opportunity to choose which vaccine he /
she wants to be vaccinated with and in
which institution. After selecting the
facility, the system displays the vacant
places and the citizen chooses the
preferred time for vaccination.

Data about vaccination, is reflected in the

NCDC immunization module.

Georgia e-Health In 2021, the healthcare system developed

app the Georgia e-Health app. It is called Is a
green passport application. Georgia e-
Health application is available both in the
App store and in the Google store. After
downloading the application, the citizen
must go through a simple registration and
all information related to vaccination will
 be displayed automatically. The program
will also display information on PCR
testing and covid-infection transmission.

Through the application, which reflects

the QR codes of the citizen, it is possible to
confirm the green status.

Thus, Georgia joined the Common Space

of Digital Passports (EU Gateway
countries). This means that Covid
certificates issued by Georgia on
vaccination, transmission of infection and
PCR testing will be included in this
common space.

Diagram 2: eHealth systems in Georgia

Healthcare Program
Regulation of Medical Auxiliary
Administration and
Activities Modules
Financial Management
Medical
HIMS Information Recourses Pharmaceutical Activity
Mediation
Infectious Disease
Immunization and Stock
Monitoring and Portal
management
Management

EMC/wHospital Electronic Medical

Mobile Application wHospital
Non-functional Records (EMR)

eHealth Systems,
developed by New HER system Patient Portal ePrescription
MoIDPOTLHSA

Georgia e-
COVID systems STOP.COV Booking.moh.gov.ge
Health
Georgia's experience in eHealth includes the development of unified electronic reporting system for
universal health and public health programs since 2014, the National Cancer Registry since 2015, and
the Birth Registry for antenatal and obstetric services since 2016 (which included monitoring the
health of children under 5 in 2018); Immunization register and mobile vaccination application; From
2017 - electronic prescription (ePrescription) and from 2019 - electronic history of health (HER).
Besides, NCDC developed medical statistics reporting moduls on the electronic portal of health, along
with disease specific registris, such as epilepsy, neurological diseases, dermatological screening.

At the same time medical networks, hospitals and outpatient facilities developed electronic systems of
electronic medical histories. Insurance companies started developing electronic management systems
much earlier, in 2007-2010.

In 2013, National Universal Health Coverage (UHC) program has been introduced by the
government. For administrating the UNC program, Ministry of Health has developed UNC
administration system, and several registries, containing several modules.

Today, national Health Management Information System contains several components, presented on
three main platforms:

 HMIS modules;

 Other separate systems: EMC/wHospital, HER, EPrescription etc.

3.3.1 HIMS modules

Development of HIMS systems has started with huge support of USAID. Donor was participating in
all component of HIMS project, including capacity building, strategy development and system
development process. HIMS was intended to serve UNC program. However, after introduction of
several other types of health programs, Ministry started developing their electronic management
module under HIMS. Electronic registries and statistical modules has also became part of HIMS.
Besides the Ministry, City hall and Autonomous Republic of Adjara also provides separate health
programs. Electronic management modules of those programs are also part of HIMS.

Nowadays, HIMS includes 8 types of modules and registries:

1. Administration and financial management of health care programs

2. Regulation of medical activities
3. Auxiliary Modules
4. Immunization and stock management
5. Monitoring and management of infectious diseases
6. Information sources
 7. Pharmaceutical Activity
8. Other systems (Useful links)

‘Administration and financial management of health care programs’ mainly focused on UNC program
management. Besides, electronic health program management systems of City Hall and Adjara are
also part of this section.

‘Regulation of medical activities’ consists with necessary modules for healthcare professional
certification and licensing module of healthcare facilities.

‘Auxiliary Modules’ contains several management modules of HIMS modules themselves. However,
several non-thematic modules is also added on this section, including Limits data base and module for
socially vulnerable population.

‘Immunization and stock management’ contains three modules of its profile, including mobile
application module for immunization.

‘Monitoring and management of infectious diseases’ module serves TB and HIV management
programs.

‘Information sources’ contains eHealth information portal itself, but also Emergency portal and
Hospital regionalization plan could be found here.

Pharmaceutical Activity module contains almost all pharma related modules.

‘Other systems’ which is called as Useful links under HIMS classification, contains many types of
modules and registries: including health program management modules, medication portal, birth
registries, statistical modules, as well as training modules, etc.

Overall, HIMS consists with almost 65 different modules. All those modules has been developed
separately and most of them are not connected/integrated with each other. Information, HIMS
modules’ are containing, are often duplicated. Thus, different systems require the same inputs and
users have to make same input for several modules. From provider side, they have to fill out multiple
modules with the same information. From Ministry’s perspective, they often have to deal with
information from multiple modules and those information often differs from each other. Thus,
overall information from HIMS is low quality and integration between the modules is very low.

All those facts also raises the question of user friendliness of HIMS.

Besides the fragmentation and functional duplication of the HIMS modules, difficulty in eHealth
project management is obvious. There is a problem on almost every level of the project life cycle. On
the first stage, initiation of system ideas could come from many different sources, however, those
people usually are not familiar with the specificity of the system development process and also their
ideas usually are not translated and approved as a projects and detailed specifications of the system is
not created at all. Also cost-effectiveness or expected quality is not known in advance. Also all
relevant stakeholders are not usually involved in the process and most of them are not familiar even
on the existence of some particular systems. As a resuls, many systems are very low quality and
doesn’t reflects stakeholder expectations. Due to such ambigious process, there are several modules,
which has developed, but are not functioning. This process rises question of effectiveness of eHalth
management proceses in the Ministry.

On the developing stage, usually international standards, such as HL7 is not considered. Also
stakeholder engagement is the process is very low and the process usually takes a lot of time. As a
result, from developing perspective, modules are finalized, but it does not reflectes stakeholder
expectations and needs to be restructured again.

On the implementation phase, usually trainings are not provided to all relevant stakeholders. Thus
they often have issue in using particular module. Also for some stakeholder, existence of some
system, and obligation to enter particular information in it, is unknown. As a resuls, data within the
system are not always accurate and the Ministry could not always relay on them.

Regarding the system evaluation phase, it usually does not happen. Thus system owners and
developers often does not have any feedback on system, which means they are not improving.

As a result of uneffective management, several modules have been developed, which dos not
functioning, or functioning only partially. Also some modules are not user friendly, and usually
accumulated data are not reliable.

3.3.2 Other Separate systems

EMC/wHospital (Non-functional)

Along with diversified, module based registries and systems, there is absolutely different type of
platform by EMC: EHR and Doctor/Hospital Portal and Mobile Application. This system has been
purchased from EMC Company.

The EHR module is intended for the registration and storage of clinical information as well as for the
provision of medical services. The financial information and financial management provided by
HIMS remains within the scope of HIMS.

Information is stored in the EHR module repository both manually and through the Doctor / Hospital
Portal module web form module, as well as through the existing HIS clinic WEB service.
Doctor / Hospital Portal and Mobile Application - The modules gives an access to clinical, reference
and financial information for doctors, staff of the Ministry and citizens of Georgia, in accordance with
the web portal and mobile application. This module also allows to record the facts of planned and
unplanned medical services, cases of patients' visits to polyclinics, accommodation, services as
provided by the state guarantees and planned cases, which were paid from other sources.

EMC/wHospital and HIMS were developed jointly, intended to exchange bilateral information.
Financial data, which is registered through Doctor / Hospital Portal and EmC and mobile application,
was possible to be transmitted to HIMS and vise versa.

The system from EMC has been purchased in 2014 by the Ministry, with publich money. The cost of
this purchase was several million. However, the Ministry has not managed to correctly define the
system goals and functions. As a result, currently this systems is not functional.

New EHR system (Functional)

The EHR system is a digital repository of data on a patient's state of health.

The purpose of the EHR system is to collect, store, share, and process electronic records of patient
health status from authorized persons, and thus facilitate the development of a continuous, effective,
patient-centered, and quality, integrated health care system.

The EHR system includes information collected by an independent medical practitioner (hereinafter
referred to as a physician) during any hospitalization episode or outpatient visit. System has Doctors’
Page, Patients’ Page and Analytical Page.

EHR has been developed by the Ministry with its owned resources and has become functional since
the January 2019.

State Electronic Prescription System (ePrescription)

Electronic recipe involves electronic information through bilateral exchanges between the doctor and
the distributor, either directly or through an intermediate network.
Pilot phase of ePrescription project has been started by 1st of August 2016 in Tbilisi region. Every big
and middle size pharma chains (Aversi, PSP, GPC, Pharmadepot, Pharmaboom, Gea, Pharmhouse,
Impexpharm, Mermisi, Peoples Pharma…) and 15 small private pharma companies and solo
proprietors, have been informed about ePrescription project and more than 1000 their representatives
have been trained. Besides, Electronic and Video instructions for system usage have been created.

Since 2022 every doctor in the country has to prescribe electronically using ePrescription system.

Patient Portal

The purpose of the patient's portal is to increase the degree of awareness of the citizens about their
health related data, in order to ensure more informative involvement of the patient in the treatment
process, to make the processes of personal data processing more transparent.

The patient portal provides important information such as patients’ medical records, electronic
prescriptions (prescriptions), information about the realization of prescriptions in the pharmaceutical
network. The same page allows the patient to get information about the processing of their personal
data.

Telemedicine

The European Union (EU), 4 UN organizations (WHO, UNFPA, UNICEF, UNOPS) and the Ministry
of IDPs from the Occupied Territories, Labor, Health and Social Affairs of Georgia launched a new
initiative on digital health: Minimizing the impact of the COVID-19 outbreak in Georgia through
telemedicine and digital health solutions.

Under this new EU-UN action, 200 rural facilities will receive basic equipment and another 50 will
receive telemedicine equipment to support the safe management of COVID-19. At the same time the
new equipment will be used to ensure uninterrupted access to health care for persons with chronic
conditions and provision of routine health services for children. Health care providers will also be
invited to participate in online training to improve and expand their capacity to provide quality
primary health care (PHC) services.

Digital COVID information management technologies

Since the April 2020, after COVID -19 has begun to spread, Ministry started adopting special mobile
application – STOPCOV. The app is developed in Austria and has been successfully used in many
western countries, as well as in Australia and Japan. Downloads are available from the App Store and
Google Play, and it’s completely free.

After downloading the app, user will be given a unique ID, which allows her to completely
anonymously identify social contacts between users of the app. Cases of contact of a certain duration
and distance, in encrypted form, are stored locally in the memory of both users' smartphones. If any
person is confirmed to have COVID-19, those who have been in contact with the confirmed case in
the last few days will receive a warning, instruction - to stay in self-isolation and contact the
authorities immediately.

While COVID-vaccines appear in Georgia, the Ministry presented new web based application -
https://booking.moh.gov.ge/. The main function of the app is to provide booking places for Covid
vaccination. The system includes all vaccine providers and gives information about free sites for
particular day. The citizen has the opportunity to choose which vaccine he / she wants to be
vaccinated with and in which institution. After selecting the facility, the system displays the vacant
places and the citizen chooses the preferred time for vaccination.

Data about vaccination, is reflected in the NCDC immunization module.

In 2021, the healthcare system developed the Georgia e-Health app. It is called a green passport
application. Georgia e-Health application is available both in the App store and in the Google store.
After downloading the application, the citizen must go through a simple registration and all
information related to vaccination will be displayed automatically. The program will also display
information on PCR testing and covid-infection transmission. Through the application, which reflects
the QR codes of the citizen, it is possible to confirm the green status. This app is developed based on
European standard. System is compatible and all data are interchangeable. Any citizen can submit
this app and travel around the world using it. Thus, Georgia joined the Common Space of Digital
Passports (EU Gateway countries). This means that Covid certificates issued by Georgia on
vaccination, transmission of infection and PCR testing will be included in this common space.

Interoperability

The success of the national healthcare system is based on the adoption of interoperability standards.
These standards can be used to regulate health system quality assurance and safety mechanisms,
overcome barriers to interoperability between different systems and creates possibility for developing
analytical direction.

Georgian national eHealth system has adopted some clinical and data exchange standards. Previous
strategies have declare that the Ministry would use HL7 technologies interoperability standards to
enable integration with the HMIS and EHR portals. However, while the use of HL7 is accepted, there
is no sufficient knowledge available to exploit its full benefits. Besides, there is no official regulation,
which would oblige using HL7 standards to the Ministry and/or private sector.

There are particular clinical standards, unified terminology, for the transition of information
electronically, which enables unified terms to be used to describe symptoms, diagnosis and treatment.

1. International Statistical Classification of Diseases and Health Problems, tenth review (ICD-10) - A
system of rubrics in which a specific nosological unit is included in accordance with the accepted
criteria. The purpose of ICD is to create conditions for systematic registration, analysis, interpretation
and comparison of mortality and morbidity data obtained at different times in different countries and
regions. ICD is used to translate verbal formulations of disease diagnoses and other health problems
into alphabetical-numeric codes that allow easy storage, retrieval, and analysis of data.

2. Nordic Classification of Surgical Procedures (NCSP) - Developed by the Nordic Medical Statistics
Committee (NOMESCO) in 1996. It is well structured; Flexible to use; Compatible with ICD-10;
Includes a list of approximately 13,000 interventions; It is updated annually; NCSP is the basis of the
NORD DRG system.

3. International Primary Health Classifier ICPC-2-R Second Revision – International classification of

symptoms, diagnosis and interventions for primary care.

4. Laboratory Classifier - Developed by the Ministry, as there is no uniform approach to the operation
of laboratory services in the world. Thus each country sets up its own laboratory service according to
the level of development of the country's healthcare system. The classifier maintains the logical
structure of the classifier construction.
Hypothesis 3: Country has established Health Information System and relevant infrastructure, which
is interoperable and based on EU standards. EHR, eRx and all the primary eHealth systems are on
place.

Findings:
 There is no unified architecture of the national eHealth system.
 The current architecture of the HIMS system is based on the module principle, but each
module contains a lot of duplicate information.
 Historicity of information does not exist in several processes.
 There is no individual electronic information about the patient's health status. Patient data is
scattered across a number of separate locations, accessed from a variety of modules.
 Information is accumulated in the HIMS system only about those patients who have received
funding under the state program. Based on these data, it is impossible to obtain
comprehensive medical statistics needed to improve the level of medical care.
 There is no single interface for the medical provider in which he can see all his activities. It
also works in several separate modules and fills in lots of separate forms. The medical provider
has many separate specialized functions but does not have a utility tool.
 The use of password authentication poses a threat to the confidentiality and accuracy of
medical and financial data transmitted and stored in the HIMS system.
 Lack of a logical repository of data for the e-health system at the national level.
 Lack of a unified full-featured integrated HIMS artisan.
 Low level of standardization in key areas such as interoperability and clinical standards
 Managing the eHealth projects are ineffective, resulting in low quality systems and often
waste of recourses on the systems, which does not even functioning.

Recommendations:
 Unified architecture of the national eHealth system should be created.
 Fragmented HIMS modules needs to be integrated and information needs to be transferred.
 HIMS modules, EHR, ePrescription and several other systems needs to be integrated.
 Modules needs to become user friendly, where all information on patients will be easily
accessible.
 Ensure patients’ access on their health information and their control over them.
 High interoperability level and clinical standards needs to be ensured.
 High level eHealth projet management standards.
3. 4. Innovation and Research in eHealth
The use of digital technologies presents new innovative prospects for the future of healthcare.
Development of the new eHealth technical solutions can have the power to revolutionize traditional
medicine through patient-centric and data driven healthcare. However, certain challenges remain to
the development and implementation of new solutions.
Currently, there is no proper eHealth innovation or research support program in the county. The
Ministry doesn’t provide any incentive scheme for private sector. In 2010, when government started
making first steps towards eHealth, donor organizations have accumulated funds, which enabled
eHealth direction to develop. Later, government started investing in developing different eHealth
systems, hiring professionals and strengthen IT infrastructure. One of the biggest investment,
government made in eHealth field, was in 2014, when the Ministry has purchased platform by EMC:
EHR and Doctor/Hospital Portal and Mobile Application.
Usually, developing of state level eHealth systems is being done with heading of the Ministry.
Ministry often refer to donors for attracting sufficient funds for project development and
implementation. Thus, on national level, purchasing and developing of innovative platforms is manly
done by the Ministry, with help of donors.
Government itself does not have any particular public support funds dedicated for eHealth
development outside the Minstry. Innovations in private sector is mainly done by business
themselves. However, the Ministry of Economics and Sustainable Development has established
Georgia’s Innovation and Technology Agency (GITA), which aims to create an effective system in
Georgia whereby innovation and technology can be developed, as well as to promote the
commercialization of innovative knowledge in order to incorporate the latest technologies into all
economic sectors and to create the necessary platform for innovative development.
GITA has several project, stimulating development of innovations in various fields. This organization
gives small grants for innovation startups. Since 2018, several eHealth innovative projects have gained
financial grants. Among them:
 MyDoc – AI based online communication system, “medical messenger”, which would enable
to implement the treatment process with high quality and fast and secure ways.
 My Drug App – allows patients to buy any prescription drug at any pharmacy at less than
wholesale price.
 Dentos – Dental Platform – First cloud based dental platform in Georgia, which is web based
service. This platform creates a universal communication bridge between costumers and
businesses. Simplifies business delivery.
 Insurewise – Provides online solution, and consulting services in the field of commercial
insurance and enable customers to search, compare, buy and manage insurance products
purchased on the platform.

Thus, there are limited possibilities for developing an innovations in eHealth field.
Research in eHealth field is quite a rare thing. There are no particular program or project, which
would be dedicated to eHealth development. An exemption is studies, conducting to evaluate the
state of play in eHealth. Such studies mainly have been done with EU funding.

Thus, the country neither have research funds to support eHealth research programmers nor provide
incentives or dedicated funding to the private sector for the development of eHealth applications and
services and research in eHealth. Similarly, Georgia does not provide funding mechanisms or
initiatives to support the use of eHealth services among citizens.

Hypothesis 4: Country has policy and effective mechanisms, supporting innovations in eHealth and
development of new eHealth technologies.

Findings:

Georgia does not have dedicated public funds supporting innovation development and/or research in
eHealth field.

Recommendations:

Government’s support to the innovation and research in eHealth is crucial for future development of
the field. Thus governments needs to invest in this field.

3.5 Capacity, Competence, Resources

Funding in eHealth development and operation in Georgia is rather scarce. None of the Institutions
have been exclusively dedicated to ensure adequate funding to develop and operate the eHealth
domain. The operation, maintenance and continuous development of eHealth services, as well as the
expansion of IT solutions, are typically funded by with international organizations’ funds (i.e. USAID,
World Bank etc.), and only sometimes by the state budget.
Since 2021, when ITA has established, this organization should become responsible to ensure
sufficient capacities and resources for maintaining and developing the eHealth direction. However,
there is a perception within ITA, that they are responsible only for technical maintenance of eHealth
systems. Thus, they don’t take responsibility to increase capacities and competencies in eHealth.
Development of digital skills in eHealth is one of the most important direction and enabler of wide
implementation and use of eHealth systems. However, the Ministry or any it’s LEPLs do not have any
plans to this direction. Developing digital skills is limited with rare training for healthcare
professionals in order to teach them particular system/module. There is no activities oriented on
improved citizens’ digital skills.

On broader level, as part of Georgia’s programme on Broadband Infrastructure Development, the

government of Georgia in 2020, has approved Strategy for the development of broadband networks
2020-2025. The strategy aims not only creating broadband infrastructure, but also establishing
Georgia as a digital and information hub in the region. According to the strategy, target indicators
include to provide most of the population with high-speed, high-quality internet access by 2025.
The strategy also aims at upgrading knowledge and skills, leading to employment growth. Strategic
goal # 3 is dedicated to the development of digital skills and increase demand on it. It includes 3
tasks:
1. Creating regional and local centers to increase demand on digital products.
2. Develop digital skills
3. Promotion of digital economics.

Overall, there are no dedicated framework, enabling creating and developing digital skills
improvement projects in eHealth field.

Hypothesis 5: Country has established mechanisms for increasing eHealth competencies, including
university programs and separate training programs/qualification courses intended to improve digital
skills of citizens in eHealth.

Findings:

There are no dedicated framework, enabling creating and developing digital skills improvement
projects in eHealth field.

Recommendations:

 In order to enable developing of eHealth field, government needs to improve digital skills of
citizens and health service providers by intensive training in computer literacy and eHealth
systems.
  eHealth is very difficult field. Developing the field requires quite large investment. After
proper eHealth policy will be defined, cost of its’ implementation should also be estimated
and relevance should e assessed.

3.6 International Cooperation, Projects, Initiatives

eHealth development in Georgia has started with the support of donors. In 2010, in order to develop
basic health data management systems, the Ministry started cooperation with USAID. This
organization largely contributed in development of HIMS in many ways. First of all, they have
financed major part of the project. Moreover, they played crucial role in eHealth capacity building.
They have developed the concept and strategy on eHealth. But their major contribution was
developing HMIS systems – Modules.

Ministry has close cooperation with EU under the Eastern Partnership. For harmonization digital
markets between EU and EaP, EU has established EU4Digital platform. Through the EU4Digital
initiative, the European Union supports the development of harmonized national frameworks for
eHealth, both among EaP partner countries and with the EU.

In support of these goals, the EU4Digital Facility will:

 Develop eHealth harmonization guidelines and standards for the EaP region
 Establish a cross-border eHealth platform in the EaP region
 Involve the region in relevant EU projects, programmers and initiatives

I order to facilitate eHealth development and harmonization, in 2016 eHealth Network has
established under EU4Digital initiative. Georgia was leading the network.

The Facility supports the actions of the EU4Digital eHealth network include:

 Establishment of a platform for the exchange of information and expertise on eHealth

 Capacity building of eHealth institutions, communities and professionals in EaP countries
 Development of recommendations for harmonizing eHealth policies
 Pilot cross-border eHealth among partner countries and with EU Member States

By supporting efforts to develop eHealth systems and ensure collaboration across borders and with
the EU, EU4Digital will deliver benefits for patients, as well as health systems and professionals.
Ultimately, improvements in eHealth will result in healthier citizens, greater efficiency in the
provision of care, more responsive insurers, and better regulation.

In September 2021, EU, along with UN organizations (WHO, UNFPA, UNICEF, UNOPS) has enabled
a launched of new telemedicine project, under which 200 rural facilities will receive basic equipment
and another 50 will receive telemedicine equipment to support the safe management of COVID-19.
Recently, EU has supported the Ministry to develop National Strategy on Health Protection 2022-
2030.

In the future, the Ministry is planning to develop separate eHealth Strategy under close cooperation
with WHO and WB.

In Georgia, the NCDC has taken a lead in educating medical personnel and staff throughout the
country, drawing on the experience gained during the recent pandemic.

With Swedish funding, UNDP will assist the NCDC in establishing an e-learning platform to provide
doctors, nurses and administrative staff with an opportunity to attend training courses and
certification programmers, communicate, exchange experience and receive practical advice from
NCDC experts.

WB is contributing in human capital development, Primary healthcare development, eHealth

development for Primary care.

ADB, Japan Development Agency and several UN agencies are providing technical support for
eHealth system development.

Caritas Czech republic in Georgia and Czech development Agency contributing in development of
healthcare sector in Georgia in many ways. One of the project, they are implementing is ‘Support to
primary healthcare strengthening in Georgia’. Project aims to strengthen primary health care through
the introduction of primary health care (PHC) quality management instruments, the development of
countrywide, comprehensive IT solutions for primary healthcare and the updating of qualification
standards and requirements and the establishment of career-long learning programs for primary
healthcare professionals. As a result of the Project activities:

 A new standardized e-Management Information system, including local Electronic Medical

Records, Stock Management, Billing module, , will be developed;
 Countrywide E-Queue Management, Telemedicine and E–Referral Management Systems will
be created;
 A Countrywide Electronic Medical Records Repository for PHC services will be developed;
 Data collection/synchronization and analytical modules for primary healthcare will be
expanded;
 Village doctors and the staff of Primary Health Care centers will be trained in the use of the
new e-MIS and other IT systems developed within the project scope;
 Clinical practice guidelines and care pathways for Primary Health Care will be updated and
village doctors will be trained in the use of the tools at target locations;
 Qualification standards and requirements will be developed for PHC providers;
 Online learning modules for PHC will be developed in accordance with the already adopted
clinical practice guidelines and 100 family physicians will be trained through these modules;
  A facility-level performance management system will be introduced at target locations as part
of the quality improvement loop;
 A laboratory information system will be built for effective COVID-19 surveillance
 The emergency response capacity of public health services and infection disease specialists in
response to pandemic/epidemic challenges will be strengthened through the introduction of
the laboratory information system.
 The Projects’ activities will support an introduction of a result-based finance mechanism,
which will be connected directly to the quality of service and will be based on different
indicators assessing the quality of medical service provided by PHC facilities.
Hypothesis 6: Country has a close cooperation with EU on eHealth related issues, including
negotiations on cross-border health information exchange. There are public and private platforms,
enhancing eHealth sector through the country/region.

Findings:

Country has cooperation mechanism with EU and other donor organizations. EU has conducted study
of eHealth systems two times, and draw roadmaps for harmonization eHealth fields between Georgia
and EU. However recommended actions has not took place yet and planned actions are not being
implemented.

Recommendations:

 In order to ensure active harmonization process with EU standards, the Ministry needs to
ensure proper implementation of harmonization roadmap.
 Development of eHealth field requires high level of capacity, expertise and funds. Also public
funds in eHealth is quite limited. Thus the Ministry should work on attracting an external
recourses and expertise.

4. Media Analysis

Table 6. Analysis of the official websites of the authorities, service institutions responsible for the
functioning of the national e-health system, and state statistics bodies.
  
Name of Publication Link to publication Type of
publication / site title publication
MoIDPOTLHSA Official https://www.moh.gov.ge/ Website
website of
MoIDPOT
LHSA

MoIDPOTLHSA Contact https://www.moh.gov.ge/ka/feedback/ Contact

Page. page of
Official MoIDPOTL
website of HSA.
MoIDPOT Hot line
LHSA

MoIDPOTLHSA Electronic https://www.moh.gov.ge/ka/695/  Description

Health , legislation
Record and
guidelines
about EHR

MoIDPOTLHSA ePrescripti https://www.moh.gov.ge/ka/664/eleqtronuli- Description,

on System receptis-sistema legislation
and
guidelines
about
ePrescriptio
n

MoIDPOTLHSA New https://www.moh.gov.ge/ka/news/6212/ News about

eHealth starting
Project has new
started telemedicin
e project

MoIDPOTLHSA Unified http://ehealth.moh.gov.ge/Hmis/Portal/ HIMS

eHealth Default.aspx modules
system

MoIDPOTLHSA Announce http://ehealth.moh.gov.ge/Hmis/Portal/ Includes

ments for MessageHistory.aspx the history
healthcare of
providers announcem
 ents for
healthcare
providers

NCDC Portals of https://portal.ncdc.ge/Pages/User/Legislation.aspx/ Portals of

NCDC NCDC

NCDC Contact https://portal.ncdc.ge/Pages/User/ContactUs.aspx Provides

Page contact
information
and Hot
Line

classifications.mo Portal for http://classifications.moh.gov.ge/Classifications/ Portal for

h.gov.ge medical Pages/ViewICD10.aspx medical
classificatio classificatio
n n gives
instructions
how they
should be
used. There
is video
lessens as
well.

SSA Contact http://ssa.gov.ge/index.php? Indicates

Page lang_id=GEO&sec_id=21 contact
information
and Hot
Line

NHA Official https://nha.gov.ge/ge/home Includes

website contact
details and
Hot Line

RAMA Official http://rama.moh.gov.ge/ Includes

website contact
details and
Hot Line
 RAMA Electronic http://rama.moh.gov.ge/geo/list/7/sameditsino- Includes
Services saqmianobis-kontroli information
about their
digital
systems

EU4Digital eHealth https://eufordigital.eu/geo/countries/georgia/ Description

program website field of
EU4digital
activities
towards
eHealth
direction

There are several sources, citizens and all interested persons can access an information regarding the
development in eHealth field.

First of all, there is the website of MoIDPOTLHSA. On the main page, interested person can find the
information regarding eHealth systems. There is special sections, where all news is published. Thus
citizens can access the news section easily. All news on eHealth development are also published
there. Besides, there is contact page on this website, indicating the contact email and phone number,
as well as number of Hot Line, which is accessible for every citizen. Hot Line is responsible to guide
citizen in getting information, they require.

Most importantly, on the main page of MoIDPOTLHSA official website, separate section is dedicated
to eHealth related topic. There is the list of four icons:

 ePrescription system
 Electronic Health Records
 eServices
 Information Portal

By clicking ePrescription, website will be directed to ePrescription information page. There are
collected all information, related ePrescription: small description of the system, website,
announcements, legal acts, and guidelines for doctors, for healthcare managers, for pharmacists, for
citizens, video lessons for every types of users. Also there are Q&A section, answering all main
questions, system users could have. Besides, on this page list of group II and group III medical
products can be found.
Also there are special instructions for Vendors – developers of private EMR and private
ePrescriptions systems. This document gives instructions on integration of state ePrescription system
to private Pharma systems and private EMR systems.

Also, this section gives information on polypharmacy management, which is directly linked to the
ePrescriptions system. Since cases of polypharmacy should be detected from ePrescription system.
There are special legal act and electronic and video guidelines for this function.

The second icon is Electronic Health Records (HER), which redirects website to EHR information
page. This page also gives information on EHR, its web address, Instructions for Primary healthcare
facilities, Ambulatory facilities and Hospitals. Also there are guidelines for Citizens. Information
regarding integration between state Electronic Health Record Systems and private EMRs is also
given.

There are list of several other eHealth services. This section includes list of medical professions,
registry of medical products, and page for printing the recipes.

On the same page, there is link to information portal. However, this page does not give full basket of
information, different users of eHealth system needs. There is only very limited information, most of
which is quit old and is not relevant any more.

The final link of eServices, which redirect user to the list of HIMS modules. On the first page, user
also can see announcement, which could be relevant for the users of those modules: announcements
include information of the recent changes in legal acts, changes in procedures and existing
instructions, about the approval of new legal acts authorities, etc.

NCDC has created separate portal, listing the existing eHealth systems under their management. By
clicking the particular system, webpage is redirecting to authorization page. However, this page does
not gives any instruction on how those systems can be used. Also majority of the systems are
intended for hospitals. The only section, which could be interested for patients, is the section of
‘applications’, which includes 2 applications: immunization app and ‘I Quit –Tobacco control’.

Also this portal includes contact page, which also contains number of Hot Line.

The rest of the LEPLs’ pages contains only limited information on eHealth. They all have several
eHealth systems under their usage. However any guidelines, how those systems could be used, could
not be found. SSA website contains limited information on eRecipe portal, from where material
recipes could be printed.

RAMA and NHA has separate section on their digital programs. However, by clicking them, website
is redirecting to authorization pages. So information about those programs is not written anywhere.
It worth mentioning that Information Technology Agency (ITA) does not yet has their own website.
Thus, there is very limited information how this agency is organized, how it is managed or what their
main products are. Also contact information of ITA is not available.

EY4Digital Platform includes information dedicated to eHealth systems in Georgia. It gives

information how eHealth direction is developing in EaP and how EU supports those 6 countries.
Success cases are also given in news section.

In conclusion, there is no unified platform, where all eHealth platforms would be consolidated and
collected. Different systems are scattered on different pages:

eHealth.moh.gov.ge - includes the list of HIMS systems. However, there is no information on those
systems. By clicking the particular system link, website is redirected to authorization page. There is
no information on the functional qualities of the systems. Neither the information on their main
users, instructions, related legal acts, nor brief history are available. Also neither of those systems are
intended to be used by the patients/citizens. Thus, none of those information, collected by 45
systems, are available for the citizens.

portal.ncdc.ge – contains information and list of modules under the management of NCDC. There is
the list of almost 30 systems, including registries, modules, and applications. However, there is not
any information regarding the functions or aims of those systems. Also user guides are not accessible
from this portal. The only systems, usable for citizens, are application section.

SSA, RAMA and NHA websites contains information about some eHealth systems, under their usage,
but there is no guidelines of description of the systems either.

The only systems, on which information could be found, are EHR and ePrescriprion systems, which
are published on the website of the Ministry.

 Table 7. An analysis of the media that most intensively covers the work of the national eHealth
systems:

Name of Publication Link to publication Type of The

publication / title publicatio nature of
site n the
publicati
on:
 GNH –  eHealth is  https://ghn.ge/news/191707-elektronuli-  Describes  neutral
online the future of jandatsva-meditsinis-khvalindeli-dghea- benefits of
newspaper healthcare sergo-chikhladze eHealth
on
country
level

EU4Digital Analysis of https://eufordigital.eu/library/analysis-of- This neutral

the current the-current-state-of-ehealth-in-the- analysis of
state of eastern-partner-countries/ the
eHealth in current
the Eastern state of
partner eHealth in
countries(20 the
20) Eastern
partner
countries

EU4Digital Common https://eufordigital.eu/wp-content/ Research neutral

Guidelines uploads/2021/03/Common-Guidelines-for- paper
for eHealth eHealth-Harmonisation-and-
Harmonizati Interoperability.pdf
on and
Interoperabi
lity

EU4Digital EU4Digital https://eufordigital.eu/eu4digital-meeting- News on neutral

meeting focuses-on-development-of-ehealth- EaP
focuses on strategies/ eHealth
development network
of eHealth
strategies

Online Since 2018, https://jandacva.ge/2018-wlidan- News on neutral

newspaper ePrescriptio eleqtronuli-receptebi-savaldebulo-khdeba/ ePrescripti
n becomes on
mandatory

Online ePrescriptio https://sputnik-georgia.com/20220301/ News on neutral

newspaper n becoming dgeidan-eleqtronuli-receptebi- ePrescripti
 mandatory amoqmedda-264870807.html on
from today

Online ePrescriptio https://metronome.ge/story/67980 News on neutral

newspaper n –From ePrescripti
now, doctor on
can
prescribe
electronicall
y

Online Georgia is https://tabula.ge/ge/news/588674- News on neutral

newspaper moving to sakartvelo-elektronuli-retseptebis- ePrescripti
ePrescriptio sistemaze on
n

Online EHR will be https://imedinews.ge/ge/politika/93063/ News on neutral

newspaper in pilot patsientebis-eleqtronuli-istoriebis-sistema- EHR
mode until 15-aprilamde-satesto-rejimshi-imushavebs
April 15

Georgian About EHR http://gsa.ge/ehr/ News on neutral

Dental EHR
Association

Online From https://1tv.ge/news/15-ianvridan- News on neutral

newspaper January 15, janmrtelobis-mdgomareobis-shesakheb- EHR
EHR will eleqtronuli-chanawerebis-sistema-
take a start amoqmeddeba/

Official STOP.COV https://www.moh.gov.ge/ka/news/5060/ News on Neutral

website of App – main STOP-COVID-aplikacia---xSirad-dasmuli- STOP.CO
MoIDPOTL questions kiTxvebi------ V App
HSA and answers

Online STOP.COV https://www.radiotavisupleba.ge/a/ News on Neutral

newspaper App has 30558856.html STOP.CO
begun V App
functioning

Online STOP.COV https://bm.ge/ka/article/stop-covid- News on Negative

newspaper App, for aplikacia-romelic-naxevar-milionamde- STOP.CO
which the dajda-gauqmda---ras-ambobs-saministro/ V App
Ministry of 74037
Health gave
half million
public
money, has
stopped
working.
Comments
from the
Ministry.

YouTube STOP.COV https://www.youtube.com/watch? Instructio Neutral

App v=7k7hPJlTXY8 n for using
STOP.CO
V App

NCDC Georgia https://vaccines.ncdc.ge/blog/2021/11/17/ News on Neutral

website eHealth for georgia-e-health-aplikatsia-e-c-mcvane- Georgia e-
Green Pass pasportisthvis/ Health app

Online Georgia https://ghn.ge/news/274753-georgia-e- News on Neutral

newspaper eHealth – health-rogor-visargeblot-mtsvane- Georgia e-
How should pasportis-aplikatsiit-ganmarteba Health app
Green Pass
app be used

Online Georgia https://bm.ge/ka/article/georgia-e- News on Neutral

newspaper eHealth – health---ase-hqvia-aplikacias-romelic- Georgia e-
App, which moqalaqis-kovid-statuss-gansazgvravs/ Health app
defines 95581
citizens
COVID
status

Online Georgia https://1tv.ge/news/giorgi-ghibradze- News on Neutral

newspaper eHealth – aplikacia-georgia-e-health-gamoiyeneba- Georgia e-
App is used evrokavshirs-plus-25-qveyanashi-aseve- Health app
by 25 EU dzalashia-kovid-19-is-dabechdili-barati-
 members covidpass-georgia-ki-gamoiyeneba-
mkholod-sa/

Online People, who https://netgazeti.ge/news/584821/ News on Neutral

newspaper have been Georgia e-
vaccinated Health app
abroad, will
be able to
use Georgia
eHealth –
App

Media analysis showed that eHealth related topics is not actively covered by online information
platforms. There is very limited information especially on HIMS systems. One of the reasons for this
could be the fact, that HIMS systems are mainly created for medical facilities, not for citizens.

There is not much news on Patients Portal either.

However, topic of ePrescription has been covered quite intensively. The Ministry has had a few press
conference on that topic. Besides, officials of the ministry were visiting various media channels and
newspapers. Thus, ePrescription system has been covered very well. Character of information mainly
was neutral or positive.

EHR system was mentioned by several news portals and TV shows. But global coverage was not
ensured.

COVID related applications attracted more interest from media side. STOP.COV and Georgia e-
Health applications were covered intensively by online news agencies, TV channels and social
networks. Most of the information have been positive or neutral. However, after STOP.COV has
been abolished, a few negative articles have been published.

Overall, coverage of eHealth related issues is not ensured. The Ministry and other stakeholders are
not actively working towards this direction. Showing the news and other types of information on
particular eHealth system, would help implementation of those systems, especially when system is
intended to be used by citizens.
5. Annexes

Annex 1: Information Sources,

Websites:

Official website of MoIDPOTLHSA - https://www.moh.gov.ge/

Electronic Health Record information page - https://www.moh.gov.ge/ka/695/

Information on ePrescription System - https://www.moh.gov.ge/ka/664/eleqtronuli-receptis-sistema

Unified eHealth system website - http://ehealth.moh.gov.ge/Hmis/Portal/Default.aspx

Portals of NCDC - https://portal.ncdc.ge/Pages/User/Legislation.aspx/

NHA Official website - https://nha.gov.ge/ge/home

RAMA Electronic Services - http://rama.moh.gov.ge/geo/list/7/sameditsino-saqmianobis-kontroli

Reports:

1. eHealth Study Report HARMONISATION OF THE DIGITAL MARKETS IN THE EASTERN

PARTNERSHIP, 2017, under Short term high quality studies to support activities under the
Eastern Partnership HiQSTEP PROJECT
2. Analysis of the current state of eHealth in the Eastern partner countries, 2020, under
U4Digital: supporting digital economy and society in the Eastern Partnership
3. Four packages of Recommendations by GeoCase, 2021

Annex 2: Questionnaires,

1. eHealth Legislation and Policy

- Are there clear eHealth policy/strategy in the country?
- Are there separate policy/strategy on telemedicine and/or mobile medicine or interoperability?
- Is the current situation in policy development and implementation satisfactory?
- List the most profound problems/challenges/deficiencies in eHealth policy making.
- In your opinion, how eHealth policy making should be organized? What are the main priorities
in this direction?
- -What are the main priorities for recent eHealth governors?
- Which legal acts, currently adopted in the country, are fundamental in the development of the
eHealth direction?
- Which legal acts are regulating development of particular eHealth systems?
- Which legal acts are regulating telemedicine and/or mobile medicine, interoperability?
- Regulation of healthcare data privacy protection and Patient's control over privacy protection
- Regulation on eHealth systems, related to COVID management
- Regulation of Big/Open Data, IoT in health sector
- In your opinion, what are the main challenges/problems/deficiencies in eHealth regulations?
- In your opinion, how eHealth regulation should be organized? What should be the main
priorities in this direction?

2. eHealth Governance
- Which authorities are responsible to develop and implement eHealth policy/strategy in the
country?
- Which authorities are responsible to develop and implement eHealth systems? Telemedicine?
Mobile health?
- List the other most relevant authorities that should be involved in the process?
- What are the distribution of powers between the authorities?
- In your opinion, what are the main challenges/problems/deficiencies in eHealth governance?
- In your opinion, how eHealth management should be organized? What are the main priorities in
this direction?

3. eHealth Infrastructure and Services

- Please, describe existing national health information system/infrastructure/Architecture
- Dose country use Open Standards?
- Availability of interoperability infrastructure (connected and universal eHealth platforms)
- Availability of functioning electronic health record systems (EHR)/ patient summaries/ Patient
Information Systems (Patient portal) and other health information systems.
- Availability of electronic prescription systems (eRx)
- Availability of electronic medical registries, emergency response systems, telemedicine, mHealth
system/infrastructure
- Availability of digital COVID information management technologies
- Integration level with e-government architecture/infrastructure
- Using of personal data, eID-based and Non-eID access services, and other services.
- Availability of Big Data/Open data and Internet of Things (IoT) technologies in eHealth. Data
collection and processing.
- eHealth technologies in pipeline
- What are the main achievements in the development of the eHealth system in the country?
- Can you name the number of users of the particular eHealth systems in the country?
- What are the main problems/challenges/deficiencies that are the most relevant in the development
of the country's eHealth systems?
- List the actions, which, in your opinion, will solve the above listed problems / overcome challenges?

4. Innovation, Research
- Does government supports development of eHealth innovations and researches?
- Which incentives mechanisms are used?
- Please, list the particular support programs.

5. Capacity, Competence, Resources

- Are public funds available for eHealth development?
- Which authorities are responsible to create and implement digital skills development policies for
eHealth use in the country?
- How do you rate the current level of digital skills of citizens to use the eHealth system in the
country?
- What is your assessment of the level of required digital skills?
- Are there programs, projects, initiatives in the country in the field of developing digital skills of
citizens to use the eHealth systems?
- What are the main challenges/constraints in developing citizens' digital skills to use the eHealth
system?
- What steps need to be taken to improve the digital skills of citizens to use the eHealth system in the
country?

6. International Cooperation, Projects, Initiatives

- Are there any eHealth best practice exchange platforms available in the country?
- Which initiatives / projects, that are being implemented or are in the process of implementation
under cooperation with EU level, could you single out as the most successful? why?
- List the most successful initiatives/projects/programs, from your point of view, in the EU;
- Which EU initiatives / projects / programs can be applied in the country? How?
- Which EU institutions/organizations/bodies, in your opinion, should our country cooperate with in
order to develop the eHealth system?
- What forms of cooperation should be used to interact with the listed institutions / organizations /
bodies?
Annex 3: Transcripts.

Respondent: Aleksandre Turdziladze

 Deputy Director at National Disease Control Agency and Public Health (NCDC)

Format: in-depth online interview (Zoom)

Aleko Turdzelidze

Sh.J: - Is there an unambiguous policy in the field of e-health in the country? Policies, strategies,
regulations and so on that regulate this field as a unified e-health system?
A.T: - Of course, there are separate documents, but they are actually taken out of context. Something
specifically is being done to manage business processes. However, so to speak, there is no single
document that is relevant to the current state of affairs that defines how e-health should be
developed. There was an attempt to create a similar document. In 2010, a concept was written that
formed the basis of one of USAID projects. Of which I was the head, but I note once again that he too
could not reflect reality, because he was generally at the level of desire. Since no one had a vision at
that time. So weird was the word e-health in 2010, trust me, there was no way that document could
be perfect. A realistic, clear document that defines the action plan, where we are going, what it
should be, what it consists of, how the relationship between the parties, the private sector, the state,
what should develop, the register, the "emr" connection, unfortunately is not similar in the country.

Sh.J: - So, to date there is no unified approach and the administration of specific systems is defined by
separate regulations. Is it the same in NCDC?
A.T: - Of course, at NCDC we could not create country-level document.

Sh.J: - Are there any specific legislative framework, strategy or priorities in telemedicine and mobile
medicine?
A.T: - There is no legislative framework or similar document, especially in telemedicine or mobile
healthcare. There are not even separate parts in any documents, it is a field that is so obscured,
although some things are written at the level of the technical task, but as such there is no legislative
framework.

Sh.J: - Does it represents priority for government? For example, telemedicine would be very useful
during COVID management.
A.T: - There are no actions towards it. But, for example booking.moh.gov.ge platform, which was
used for vaccines by the whole population, was made with the help of the Czech Development
Agency not only for vaccination, in fact it can be used as a referral mechanism between different
services, between different institutions and also for the teleconsultation. A patient or doctor can
schedule an appointment on a platform where the google meet streaming platform is embedded.
Relevant documents would be shared here. When we were working on the topic of telemedicine, we
saw that google meet is making a claim on telemedicine. Under the terms of the license, they wrote
that for the purpose of telemedicine, 30 minutes of use. Even commercial, it's free. Streaming for
more than 30 minutes will be subject to license conditions. However, a standard consultation will not
take more than 30 minutes. Accordingly, we used Google meet. Booking.moh.gov.ge has so far been
tested only for booking vaccines. Has not gone further yet. We will observe how ITA will develop
this system, what strategies and policies it will develop in the future.

Sh.J: -Are there particular approaches to interoperability standards?

A.T: -If we are talking about data exchange, this is the HL7 standard. In fact, the recent services,
provided to the state side are done according to this standard. For example, for COVID management
purposes, we made integration engines. This is a special application with which all laboratories joined
this COVID Lab system, and all other parties receive information about the tests taken and also send
the answers. In other words, these topics were completely "mechanically" regulated. CDA 2 format
and the components of HL7 were fully embedded, however I note once again that at the legislative
level this is not defined. We just used it from a practical point of view.

Sh.J: - Has any legal act been issued in this regard?

A.T: - No, there is no such legal act anywhere, which would speak directly about the format of data
exchange.

Sh.J: -Which applications or systems were created in connection with COVID management and who
are the authors of those systems?

A.T: -Globally, 4 systems are used in connection with COVID. First, it is COVID laboratory system;
The second is booking system, where patients were vaccinated, the third is the immunization system,
where the vaccines were registered, and the fourth is the so-called "green passports" made at NCDC -
Georgian eHealth app. These 4 are within NCDC, but I remember that "Covid Pass" was made, which
was based on the same database, why and for what was it made, I still have no answer. Also, as I
know another system was made. I don’t know if it is functional.
Sh.J: - Who made the last two systems, which, so to speak, was not necessary?

A.T: - I do not know, state agencies. ITA made one, I really do not know how the decision was made
inside. As far as I know, no money was spent, they made it with their own resources and the rest of
the system was made by Sijes, the base of COVID hospitalization, but as far as I know it was not used.

Sh.J: - What can you tell us about the protection of eHealth data, how is it regulated, and how is all
this enforced?

A.T: - I think this topic is the most regulated, because when the office of the Data Protection
Inspector was functioning, they issued several orders, which are mandatory for all agencies, and
audits in this area are constantly conducted, and all agencies try not to violate, as the case is already
moving in court. So I think this issue is the most regulated, in general as far as healthcare and
information systems are concerned. Issues of data protection, confidentiality and data storage are
provided.

Sh.J: -How much does the patient manage his/her data? For example in EHR registers or somewhere?

A.T: - Cannot manage, except in EHR state systems, where there is a patient page to manage,
although there are registration problems. The medical facility must register, so if the units are
actually used. In other registers the role of the patient as such does not yet exist. There is talk of
putting a page in the Georgia eHealth app along with many other features that will allow the patient
to get information about themselves, both about vaccinations and about being tested from different
registers, and also to share their information from one doctor to another. Even EHR can be used for
sharing information from here, because in fact this app is very widely used and we do not want to
miss the opportunity to do so. It has over a million downloads and users are most important in terms
of the scalability of this system.

Sh.J: - Is there anything about cross border / interoperability?

A.T: -There is no regulation, there are opinions at the project level, although nothing is practical yet.

Sh.J: - What about big data or open data?

A.T: -Big data is quite conditional. What we may consider as big data, for China it can be funny.
There is discussion on many conferences what is considered as big data: millions of records or billions
of records. We do have millions of records in the systems.
Sh.J: - How much of this accumulated information is processed, is anyone, responsible for conducting
analytics centrally or locally?

A.T:- Just as the creation of information systems has a use culture, so this culture will be formed over
time in analytical terms. If we look at the trend over the years this culture is really growing. The
same covid for example, millions of records are analyzed daily by default to be sent to a state /
international organization and so on, for various purposes. Like medical statistical information, and
this culture is slowly taking shape, and the everyone realizes that the system is not just about putting
information in, but also extracting data and process it. A lot is thought about in this regard and has
changed compared to previous years. Conclusions are made on the basis of data processing whether
this process is going well or not. Overall, there is progress in this regard.

Sh.J: - If we move to eHealth governance, globally, who is the agency / agencies responsible for
eHealth policy, strategy, regulation across the country and who carries which function in this regard?

A.T: -If we will read the statute of the Information Technology Agency, the agency is responsible for
developing such concept, but how much they are willing and able to do so cannot really tell at this
stage, but there is one agency that should define the eHealth directions and concept of the country's
health information system. No one else has the right to engage in this matter.

Sh.J: - Previously, there was an IT department in the Ministry, in the Social Agency and so on…

A.T: -Everything is united, to get acquainted with the decision of the government on the
establishment of the Information Technology Agency, everything is written about the functions and
responsibilities.

Sh.J: - The Ministry of Health did not retain any IT functions?

A.T: - No, they did not, he was taken away separately.

Sh.J: - How often does the Health Policy Department intervene?

A.T: -It is involved in the same way, since any business process needs to legitimize. It's not just IT, it's
a functional business process, with the Department of Health in charge of the idea. They are actively
involved.
Sh.J: - When the National Health Agency was established, are they connected with the development
of electronic systems?

A.T: -Their systems are also in ITA. All systems are in ITA: pension, employment, regulation. The
ministry has left only the analytical service, which processes the data.

Sh.J: - Let's talk specifically about eHealth infrastructure, what are the main directions in terms of
systems, have any important directions been added?

A.T: - This is part of mobile health, the novelty is the Georgia eHealth app, which talks about
expanding its features to allow citizens to access their own information to manage their profiles. Data
exchange engines have also been created, which is also a new direction as we avoid parallel work in
many different systems, which is unfortunately so established as different business processes have
been done and are being done. These two areas can be distinguished in terms of mobile health, where
steps are taken for harmonized data exchange.

Sh.J: - For which other systems are Integration engines serving?

A.T: -Not any other yet. This is a slightly different principle from the classic service, since the
redistribution of responsibilities is no longer just between the developer and the system. Managers
are already involved as the system allows them to see what part of their data has not been validated.
This is a conceptually different approach, since the system is separate, in which there are forms and
the manager sees all information. He/She can put the data exchange mode in automatic mode or
verify and so on. In this form the validity runs exactly as the state requires. This system ensures that
the institutions move to the validation stage. You give the form to the other party and they are
responsible for the validation. So, this approach alleviating the situation of the Ministry in terms of
data storage, as the volume of information is growing rapidly and this approach is revolutionary in
terms of data storage.

Sh.J: - Did this system be created by your agency?

A.T: -Yes, it was entirely ours, it happened before the IT agency was formed. The system was created
in 2020. The pilot project was implemented in the first health facilities. Our goal was to evaluate the
service not only quantitatively but also qualitatively. What quality of services are provided by this or
that outpatient institution. At first it was one-sided, we took and worked in the analytical system,
then we made a two-sided, unified system, which exchanged information and redistributed
responsibilities between the parties. I think it was justified because millions of pieces of information
were exchanged and no flaws were fixed.
Sh.J: - Does our healthcare system use open standards?

A.T: -Only HL7, nothing more in terms of actual information exchange. Except for the classifiers used
to classify diseases: ICD, NCSP, and Lab.

Sh.J: - Have you had contact with 112 emergency response systems?

A.T: - I did not touch it, I cannot tell.

Sh.J: - We have said that a specific app for telemedicine and mobile medicine is built into booking,
but has not been used yet.

A.T: - Booking is not a classic booking system, it is a system of telemedicine, editing and recording.

Sh.J: - As for the patient portal, is the patient module in the EHR system the only one of its types of
systems?

A.T: - Yes for now. However, there is talk that the functionality of the Georgia eHealth app will be
expanded and a patient data page will be added. Screening, scheduled services, reminders,
vaccinations, visit booking. The concept is being prepared and we hope it will expand. In order for
the system to function actively, it is necessary to involve citizens in it. Without the involvement of
citizens, the immunization data would not have been complete either, as providers would have paid
less attention to it. Citizen activism creates a demand for timely and accurate data entry. He actually
became a citizen player and that was how it was planned.

Sh.J: - In Georgia eHealth application everything is written with a barcode, such as vaccinations, test
results etc. Since this is a universal language, how much is it used or perceived abroad?

A.T: -This is directly European standard. Fully compatible and interchangeable. Any citizen can
submit this app and travel around the world using it without any hassles or problems. That's why
everyone saves this app, owns their own certificate and can download this certificate as well as signed
up. The electronic signature is attached to a PDF file that is uploaded on behalf of the Centers for
Disease Control.
Sh.J: - We were also talking about the patient portal, earlier it was said that they were going to join
egov.ge, since they have a higher standard of patient authorization and authentication, and how far
has this idea gone?

A.T: - I do not know, I cannot answer you, I am not competent.

Sh.J: - How often are the services of the Ministry of Justice used?

A.T: - Health sector is the largest consumer for them. This is the death of a patient / organization's
identity, citizenship status, citizen's name in English and other data. It is believed that healthcare is
the biggest user of their services.

Sh.J: - What perspectives do you see for the electronic production of medical documentation?

A.T: -We, together with the Department of Health Policy, have created a legislative act that deals
with electronic medical records, however at this stage it is a draft and could not be passed.

Sh.J: - Touching the calculation module, do you have any information about primary health care
programs?

A.T: - To tell you the truth, I have a completely different view of the calculation module. Today it is
considered as part of medical histories, it was not even run as a pilot and I do not know how it
actually works. There are different business processes, calculation is calculation and medical history is
medical history. Processes must be arranged so that everyone works in their place. So the data will
not be lost either.

Sh.J: - How much is the state supporting innovation and research in this field?

A.T: - I am not familiar with such state funding. In any case, no one interferes, so to speak, and it
means that they have some opportunities. This is a very interesting topic, not at the state level, but
interested parties can access similar funds. There are also quite large grants and if a person wishes, he
can win.

Sh.J: - Talking about digital skills in the field of e-health, both from, providers (doctors, clinics) as
well as patients on the other hand.

A.T: - We launched the first electronic system based on the web on April 1, 2011, it was "Case
Registration". There is progress and gradually better quality information is coming. All this was due
to the development and accessibility of the Internet and technology. Better computers and better
internet. And increased accessibility.

Sh.J: - What is the level of equipping of clinics in your estimation, especially in the regions?

A.T: - I cannot say that I have evaluated it. There is quite a bit of increased availability in this regard,
hence there is progress as well.

Sh.J: - At the state level, is anyone responsible for developing these digital skills in providers or
patients, is any training is conducted, or is there any ongoing work in this direction? Even
considering the process of implementing specific systems.

A.T: - In the process of introducing systems, the party who is interested (business "Owner") of course
tries to actually get the training to the place to get information about the system and start the
business process. As such, a separate agency does not actually exist. But, "help desk"(hot line) culture
is being formed, which is also one of the signs of development.

Sh.J: - In terms of international cooperation in the field of e-health, do you have information and are
we involved in major projects, especially in relation to the European Union?

A.T: - Not at the level of a country project, but certainly at the level of individual institutions. For
example, registers are made in a manner, which enables international exchange of collected data. For
example the birth register is based on the example of the Norwegian birth register and why
Norwegian? Because Norway is one of the countries with the longest registers and its culture is very
high. When you make such level registers, international level collaboration is direct. I cannot say the
most, but we have worked seriously in this area of disease control.

Sh.J: - Is there any project in which you need EU assistance or "twinning" projects with them?

A.T: - There are many "twinning" projects, but in a small way. In terms of digital health, I do not
have any "twinning" project in Georgia at this stage. It would certainly be interesting, just who
should do it? Let's just say that people's qualifications need to be relevant to what we're talking about
in the business process. Finding intelligent and experienced staff is very difficult and draining. I do
not know the mechanism by which it can be maintained.
Sh.J: - To summarize, what do you see as the main problems in the field of policy, governance and
generally in the eHealth systems? What key problems or challenges do you see in these three areas,
and what recommendations would you have for fixing and improving them?

A.T: - First of all this is a very difficult field. When we started counting this with a special
international tool, it turned out that those, who have good health care system, are paying for it. It's
broken down functionally into what you pay for. First we have to find out what is the cost in this
area and then judge on relevance. I think in the first place right policy, what we want should be
define, what funding we have, then everything follows that. This field requires a lot of investment,
but it must be done properly so that the yields are large. We need to define what we want, what is
needed, how to obtain it.

Sh.J: - Do we have fragmented systems? And what should be the ideal eHealth model for you?

A.T: -The ideal scenario is to eliminate parallelism, where the complement is to be functionally
complemented and all connected to each other. Completing means that a portion of the patient
information appears in the system in large doses. Until now it could not appear because it needed a
very large foundation. This foundation is fortunately designed, dozens of systems are made.

Respondent: Ketevan Goginashvili

 Head of Division, at the Department of Policy, Ministry of Internally Displaced Persons from
the Occupied Territories, Labor, Health and Social Affairs of Georgia (MoIDPOTLHSA)
Format: in-depth online interview (Zoom)

Sh.J: - To what extent has the e-health policy or strategic documentation been developed by the
Ministry of Health?
K.G: - A separate e-health strategic document is not planned to be prepared at this stage. We think
this will be part of a larger healthcare strategy. The National Health Strategy, which went for approve
this week by the government, lists several main priorities. One of the priorities is the development of
information systems and the sub-priority will be the development of e-health. However, ITA plans to
develop a technical strategy for the eHealth, and in parallel, the World Bank and the World Health
Organization will assist us in developing a digital health strategy and action plan. In short, at this
stage it is planned to prepare a technical strategy, prepare an action plan, part of the health strategy
(eHealth and information systems) and prepare a digital health strategy.
Sh.J: - As for ITA's strategy, is it already planned or has it started working?
K.G: - I do not know, ITA will probably tell you itself. ITA will be the technical administrator of
these databases so to speak.

Sh.J: - Are there independent strategies for the development of telemedicine and mobile medicine?
K.G: - Work on a digital healthcare strategy will begin soon. The World Bank and the World Health
Organization simultaneously intend to assist the Ministry in this matter. The process of forming a
working group is underway at this stage. Then the experts of the bank will help us to select the
direction of the main goals and main priorities and to write a strategy.

Sh.J: - Is the digital healthcare strategy still planned separately?

K.G: - Yes, it will be approved separately by the government decree. I can tell you the tasks, what is
on our side at this point. The first is to strengthen digital healthcare management, with an emphasis
on creating a digital healthcare strategy. Second - Strengthen eHealth architecture and services
architecture and improve electronic data exchange system and quality. The third task is to facilitate
the introduction of digital health technologies and telemedicine services, although this will be on a
more extensive technical level in a larger strategy.

Sh.J: - Does the digital healthcare strategy address issues of telemedicine and mobile medicine?
K.G: - Yes, it includes everything. We will approximately follow the World Health Organization's
digital health strategy, the global strategy. We can take priorities and targets from there. However, in
the country it all goes a little differently, yet now it is setting foot.

Sh.J: - The next question is about interoperability, i.e. compatibility of healthcare systems, is there
any strategy for this, such as data exchange or data compatibility?
K.G: - It is showed in this strategy that all modules must be compatible. Must be compatible with
international databases. A good example of this is COVID Passports, which has shown us the need for
a uniform "interface" for data exchange at the international level, and that is what we are talking
about. The Health Policy Department is involved with the Ministry of Health.

Sh.J: - Is the Department of Health Policy involved with the Ministry of Health?
K.G: - There is only one Division of Health Policy in the Ministry of Health, in the large policy
department that works in all directions.

Sh.J: - In your opinion, what are the main problems and challenges in terms of developing e-health
policy in the country?
K.G: - At this point, the problem that might arise would be technical assistance. There is a desire,
there is also a political will to do it. Is reflected in the great strategy that must be followed. Donors
have appeared to help us. The World Health Organization has assessed the current situation and
signed a document (draft) that will be shared soon. An initial assessment has been made. See what the
problems are and provide technical assistance to solve them from two great experienced donors.
There is readiness from the inside as well. The best representatives of the IT service of all agencies are
gathered together.

Sh.J: - Turning to regulations, what are the most important and fundamental regulations for eHealth?
On which are the basic systems based?
K.G: - At this stage our regulatory environment regarding eHealth is fundamental privacy of
information, personal data, which is regulated by law. Regulation of our statistical modules are
approved by order of the Minister.

Sh.J: - In parallel with the approval of the new strategy, are there any plans to develop regulatory
norms?
K.G: - One of the tasks should be to improve the regulatory environment and develop a unified
framework in this regard. Strategy alone can do nothing if there is no regulatory environment.

Sh.J: - Are there any regulatory acts related to telemedicine or mobile medicine?
K.G: - Telemedicine is new. The first steps were taken during the COVID period. The first thing we
did was buy 50 telemedicine equipment for the village doctors. So far they are providing services, but
still not formalized. Terms such as "telemedicine" and "teleservice" are not yet well established in the
legislation. All this must be reflected and given its face in a regulatory environment.

Sh.J: - Are there any plans to expand this program in this regard?
K.G: - Of course, we are going to buy another 50 pieces. A telemedicine department is now being set
up in the holding, which will take over our assistance with regulations, as well as work on the
implementation and monitoring of regulations.

Sh.J: - As for mobile medicine, have any steps been taken in this regard?
K.G: - Several mobile applications of mobile medicine are used quite well by the healthcare system,
especially for prevention, immunization, antenatal services. Same with, say, COVID passports.

Sh.J: - Does it exist directly in the form of applications?

K.G: - Yes, we have apps at this point. Immunization, antenatal services, screening programs used and
implemented.

Sh.J: - We were talking about COVID systems, after the start of COVID, one of these COVID
applications was created, which reflects immunizations and also has a green passport function, and
has another system been created for COVID management?
K.G: - At first we had a STOP.COV that did not work, since the number of infected people increased
a lot. So it lost its meaning and was no longer actual. Second was booking system for COVID
vaccines. The app was relied entirely on the immunization app. Its expansion occurred rapidly.

Sh.J: - Talking about the main stakeholders, is anyone involved in eHealth other than the Ministry in
terms of policy making?
K.G: - Holding, ITA will be involved, international donors, an EU’s € 4 million project dedicated to
the development of digital healthcare for the management of COVID.

Sh.J: - What activities does this project involve?

K.G: - Procurement of this equipment within the project, training for using "software", training of
medical staff, as well as capacity building in ITA and the Ministry in the field of digital medicine.
Including creating guidelines.

Sh.J: - As for the other players, Social Service Agency also had a lot of modules …
K.G: - No one has modules at this stage, we transferred the modules to ITA. The agency uses only
information from these modules, which it processes and then sends. The modules are managed
through ITA, the management has moved everything to ITA.

Sh.J: - How much does ITA interfere in policy development?

K.G: - ITA is intervening within its competence- on the technical side and in terms of administering
and developing these databases- which we will not be able to do. Information security, cyber-attacks,
protection of personal information and communication between modules - all this will be on their
side.

Sh.J: - Do you see challenges in eHealth governance and if you have solutions?
K.G: - The first was clutter, it was scattered everywhere and there was a problem with the quality of
connections and data between them. That's why it was created to hold these modules in a single
format. This was the first step taken by the Ministry of Health in this direction. A strong team was
formed. The rest is already planned and taking care of all this is reflected in the strategy.

Sh.J: - Has a special unit been set up in ITA for those directly responsible for developing or managing
eHealth projects? (E.g. For managing HER, electronic prescriptions)?
K.G: - To be honest, the structure inside ITA I do not know and it is better to talk to them.

Sh.J: - Talking about specific projects, what systems has Georgian eHealth developed recently?
K.G: - EHR is introduced in healthcare for the first time, with the addition of modules where detailed
cost descriptions are available. These modules still work. Also registries. NCDC has separate modules
where statistics are collected. The Regulatory Agency has started to create a register of people with
disabilities. The new modules we have on COVID have helped us a lot to manage testing and
immunization. This is what we have at this point. Everything is legitimate and works. Some in pilot
mode, some in big cities and district centers. We have not reached the village yet.

Sh.J: - Do you have information about 112’s owned systems? For example, on the Emergency
response system?
K.G: - During the COVID period, I often had contact with 112 when patients were being managed
from their apartment. This was done through the 112 program. A patient who did not have a doctor
chosen or did not have insurance helped us a lot with the "Emergency" system to find a bed for him
or a nearby clinic.

Sh.J: - As for the patient portal, do you have a functional patient portal?
K.G: - We need to start a patient portal. Social section is prepared and there is a view on personal
information regarding pensions. In the health section you can see where you are registered and see
who your family doctor is, find contact information and so on. Work on patient-related health
services had begun, however, and work on the process was halted during the COVID period.

Sh.J: - Has the National Health Agency taken over the universal health care system and vertical
programs?
K.G: - Yes, the Social Services Agency split into two parts and left the Social Services Agency and the
National Health Agency where the health programs came out and left the social programs and outlets
on that side. Basically social systems and healthcare topics were not very compatible and used each
other less information.

Sh.J: - As for the drug agency, what can you tell us, what system do they use?
K.G: - The Drug Agency at this stage is again the regulatory agency in the form of the Drug
Department. We have a recipe system that ITA managed is an improved option now. They are now
working on drug e-registration and data analysis module for ePrescription.

Sh.J: - As for the analytical part, what portion of accumulated information analyzed and who
analyzes it?
K.G: - Part of the analysis includes ITA as an information provider for the agency. This is pretty
specific information about medicines. At this point it all happens by hand. On the agency side the
pharmacists analyze where they are. There is a separate analysis department in the ministry, which
looks at quantitative material. Its direction has its owners in agencies. ITA is simply responsible for
providing the information.

Sh.J: - How well is the huge amount of information stored in the system being used?
K.G: - I think we use very little 30-40% of the information we have. This is more the fault of the
unfriendly "interface" of the systems.

Sh.J: - What are the main problems and challenges you see in the direction of these systems and how
do you think they can be solved?
K.G: - I think the ITA Group will be the ones who will be able to capture the fragmented data and
bring it together on a single platform. Finding information from different sources will no longer be a
matter for the user. Quality monitoring should also be carried out. At this stage, the degree of
reliability of the transmitters in the various systems is very low. I think ITA's internal strategy and
the big healthcare strategy with its action plans will allow us to eliminate these problems.

Sh.J: - Does all this require funding?

K.G: - It requires large amount of money. Actually the most deficient part of the strategy is the
eHealth related goal, for which no funds are allocated at this stage. We think of working actively in
this regard and finding donors. When specific actions are identified, it will be easier to find both state
and donor funding. In fact, eHealth allows you to save money, avoid providing false information and
not paying extra for institutions.

Sh.J: - At what stage is the introduction of DRG systems planned?

K.G: - To develop this system, we bought a Scandinavian software, which was built into the funding
and case registration module. We then developed artificial codes, combinations of diagnoses and
interventions. The data entered in 2018-2019 were grouped. 66% of them could be grouped. We have
created a group that explores the logic of grouping. The data entered in the pilot mode is currently
being grouped and analyzed. Their quality and logic are checked, based on which the DRG tariffs and
the methodology of their compilation should be developed. Double funding will be launched under
DRG from January 2023. Tariffs will be calculated by both old and new methods. Reimbursement
will be made using the old method, but the calculation of the same service with the new method will
also be available on the providers’ side to ensure transparency and providers to see the real difference
between the old and new tariffs in order to gain credibility with the new system. The DRG system
was purchased in 2017 and the project was written for 4 years.

Sh.J: - Is there government support for e-health innovation and research?

K.G: - The support to eHealth is one of the main priorities for the Ministry. This is seen in the
introduction of eHealth innovations and the development of research. However, I do not think
funding for these studies will be available in the next 2 years. More likely donors should be
contributors to these studies.

Sh.J: - Who finances the development of eHealth systems?

K.G: - The main resource is placed by donors. The state has fewer resources at this stage, however
when the needs are accurately identified, then it becomes more apparent to what extent the state
should redistribute its burden to donors.

Sh.J: - Does the state has a policy on developing digital skills in eHealth?
K.G: - This is not just a problem of the ministry. It is a problem to be discussed at the government
level. The development of digital services is one of the priorities in the government's 2020-2030
strategy and the development of digital skills in their population. Especially in older people digital
skills and internet access are a problem. Strengthening digital skills requires the involvement of
different ministries. According to the unified plan of the government, various projects will be
implemented to improve the digital skills of the population, and state funding will be allocated for
this. The government's strategy is due to be approved in June this year.

Sh.J: - Do you provide training for your systems to the recipients?

K.G: - Along with the creation of electronic applications, there was a need to teach them how to use
them. To ensure this, we have posted instructions for using the systems on our websites. Volunteers
were also used for face-to-face training on specific systems.

Sh.J: - Who are your main donors?

K.G: - The European Union, WHO, the World Bank, the Asian Development Bank, and technical
assistance is provided by the Japan Development Agency, UN agencies. It is a very popular and
interesting topic and the pandemic has shown us the importance of developing this area. Universal
health care should not be tied only to the doctor. Modern digital technologies allow the patient to be
treated remotely without moving the patient over long distances. This will save costs and increase the
delivery of quality services.

Sh.J: - In what direction is the cooperation with the EU going?

K.G: - Cooperation with them is underway in the fight against COVID. This also includes eHealth. 4
million euros have been allocated. Designed for three and a half years. The UN Development Agency
is also involved in this project. There is a separate World Bank project focused on human capital
development. It will also contribute to the development of healthcare and digital medicine for the
first time. WHO technical assistance is separate. Also assist in the development of digital strategies
and the development of digital technologies in primary health care. We hope that with the help of
donors and consistent government policies, eHealth will be developed. If we want to save costs and
be accessible, universal digital healthcare must be developed.

Respondent: Information Technology Agency

  Representative of an Agency

Format: Questionnaires has been filled out independently by the representatives of ITA

1. eHealth Legislation and Policy

Question: - Are there clear eHealth policy/strategy in the country?

ITA: - There’s a e-health strategy that is currently under development by the MoH, ITA is involved,
MoH’s policy department (henceforth PD) might elaborate a bit more around this topic based on
their competences.

Q: - Are there separate policy/strategy on telemedicine and/or mobile medicine?

ITA: - To ITA’s recollection, workgroup on the further development of business procedure’s

framework governing Telemedicine is under development in coordination with WHO. The topic can
be expanded by MoH PD

Q: - Are there strategy on interoperability?

ITA: – Data interoperability is something that is constantly addressed during work meetings and is
born into mind while the development of the new services or the consolidation of the existing
systems are debated. However, there is no separate set in stone policy regarding interoperability
solely. Ensuring data interoperability will be a part of the Ministry’s ICT strategy that is being
developed.

Q: - Is the current situation in policy development and implementation satisfactory?

ITA: – There’s always room for development. We consider creation of Information Technology
Agency of the MOIDPLHSA (ministry of idps, labor, health and social affairs) as a marking of the
new period in streamlining of the processes when it comes to digitalization of the business processes
of the services MoH together with its subordinated agencies.

Q: - List the most profound problems/challenges/deficiencies in eHealth policy making.

ITA: – ITA is young agency and we have legacy systems to cope with, so called brownfield projects
to reframe. We consider tools in terms of better coordination mechanism in manner of regular
meetings and forums across the system would facilitate better common stance on key issues and
priorities.

Q: - In your opinion, how eHealth policy making should be organized? What are the main priorities
in this direction?
ITA: – Most likely the question would’ve been addressed by PD MoH

Q: -What are the main priorities for recent eHealth governors?

ITA: – We consider this would’ve been matter of discussion with PD MoH

Q: - Which legal acts, currently adopted in the country, are fundamental in the development of the
eHealth direction?

ITA: – PD MoH

Q: - Which legal acts are regulating development of particular eHealth systems?

ITA: – to MoH

Q: - Which legal acts are regulating development of telemedicine and/or mobile medicine?

ITA: – To our information the subject goes unregulated

Q: - are there any legal certainty on interoperability and/or cross-border interoperability?

ITA: – One of the salient examples of interoperability was EU DCC gateway to which ITA facilitated
adding of Georgian DCC to the system. We had to fill in and provide range of information for
successful coupling. We at ITA are ready to facilitate further integration regarding other health data.

Q: - Regulation of healthcare data privacy protection and Patient's control over privacy protection

ITA: – Most of the regulations come from general personal privacy legislation.

Q: - Regulation on eHealth systems, related to COVID management

ITA: – Government decrees are present, most likely could be addressed by MoH

Q: - Regulation of Big/Open Data, IoT in health sector

ITA: – N/A there is no separate regulation on big data

Q: - In your opinion, what are the main challenges/problems/deficiencies in eHealth regulations?

ITA: – The question most likely should be addressed to MoH.

Q: - In your opinion, how eHealth regulation should be organized? What should be the main
priorities in this direction?

ITA: – Functionality and the bare minimum of restrictions to protect data breaches and overall
stability of the systems so that not to limit further expansion of the services.

2. eHealth Governance
Q: - Which authorities are responsible to develop and implement eHealth policy/strategy in the
country?

ITA: – The policy with regard to this issue is utmost competence of the MOIDPLHSA. Its ITA is yet
another though important mean of the execution of the strategy that is ought to be developed

Q: - Which authorities are responsible to develop and implement eHealth systems? Telemedicine?
Mobile health?

ITA: – MOIDPLHSA, ITA, NHA, STATE MEDICAL HOLDING, NCDC etc.

Q: - List the other most relevant authorities that should be involved in the process?

ITA: – MOIDPLHSA, ITA and most of the legal entities of public law operating under the
abovementioned ministry. Private sector can play big role as well.

Q: - What are the distribution of powers between the authorities?

ITA: – The question might be better addressed by the MOIDPLHSA

Q: - In your opinion, what are the main challenges/problems/deficiencies in eHealth governance?

ITA: – to MOIDPLHSA. Although some EU countries have the agencies specifically working on e-
health solely.

Q: - In your opinion, how eHealth management should be organized? What are the main priorities in
this direction?

ITA: – accessibility via digitalization of the most of the existing health services is one of the main
objectives of current system, however maybe better addressed by MOIDPLHSA

7. eHealth Infrastructure and Services

Q: - Please, describe existing national health information system/infrastructure/Architecture

ITA: – the medical card of the patient is opened by the physician, where the anamnesis is created
(source is the patient), clinical diagnosis, preliminary diagnosis, medical checks, final diagnosis, form
100, prescriptions, recommendations

Q: - Dose country use Open Standards?

ITA: - NA

Q: - Availability of interoperability infrastructure (connected and universal eHealth platforms)

ITA: – although HMIS and some software can be characterized as supporting interchange of certain
data this is under development
Q: - Availability of functioning electronic health record systems (EHR)/ patient summaries/ other
health information systems.

ITA: – system exists

Q: - Availability of electronic prescription systems (eRx)

ITA: – system exists

Q: - Availability of electronic medical registries

ITA: – system is under construction

Q: - Availability of emergency response systems

ITA: – system exists

Q: - Availability of national Telemedicine and mHealth system/infrastructure

ITA: – system is under development

Q: - Availability of Patient Information Systems (Patient portal)

ITA: – the system is being planned

Q: - Availability of digital COVID information management technologies

ITA: – such systems exist

Q: - Integration level with e-government architecture/infrastructure

ITA: - Low level of integration

Q: - eID-based and Non-eID access services

ITA: – N/A under consideration

Q: - Availability of Big Data/Open data and Internet of Things (IoT) technologies in eHealth. Data
collection and processing.

ITA: – Low level

Q: - eHealth technologies in pipeline

ITA: – e.g. e-prescriptions, electronic health records mobile system and mobile applications,
telemedicine system etc.

Q: - What are the main achievements in the development of the eHealth system in the country?
ITA: - EHR system was created, is being currently implemented. Electronic medical record’s system
will be finalized, the patient’s portal is under development, electronic immunization management
will be released etc.

Q: - List the main achievements, positive changes in the field?

ITA: – Creation of the ITA as a separate institution responsible for the development and maintenance
of all systems across the MOIDPLHSA, creation of COVID management systems

Q: - Indicate the authorities and/or non-state institutions, which has played a crucial role to make the
achievements / positive developments possible?

ITA: - MOIDPLHSA, Caritas, WHO, ITA

Q: - Can you name the number of users of the particular eHealth systems in the country?

ITA: – e.g. 1400 medical facilities use e-health records system, there are registered around 2.5 million
medical cards of the patients.

Q: - What are the main problems/challenges/deficiencies that are the most relevant in the
development of the country's eHealth systems?

ITA: - The overall internet coverage in the regions and computer literacy of citizens as well as
physicians can be seen as an impediment for rapid development

Q: - List the actions, which, in your opinion, will solve the above listed problems / overcome
challenges?

ITA: – there quite frequently opposition to the digitalization of the services, as it makes cases of
ageism and disparity in income more rampant although the covid outbreak prove waiting for gradual
raise in computer literacy can be backfiring.

8. Innovation, Research
Q: - Does government supports development of eHealth innovations and researches?
ITA: – Widely, we at ITA think creation of our organization one prominent step in that direction,
the answer can be elaborated further by MOIDPLHSA itself
Q: - Which incentives mechanisms are used?
ITA: – response regarding the specific policies is preferable to be elaborated by MOIDPLHSA, though
establishment of ITA is it’s example, the organization’s agenda is full of exploring the improvement
possibilities, in tight cooperation with other MOIDPLHSA agencies many benefitting our citizens
services even outside the health systems is underway
Q: - Please, list the particular support programs.
ITA: – allegedly should be addressed to MOIDPLHSA
9. Capacity, Competence, Resources
Q: - Are public funds available for eHealth development?

ITA: – to MOIDPLHSA

Q: - Which authorities are responsible to create and implement digital skills development policies for
eHealth use in the country?

ITA: – looks as much inter-institutionary feat. Though allegedly overall will be developed under
MOIDPLHSA

Q: - How do you rate the current level of digital skills of citizens to use the eHealth system in the
country?

ITA: – leaves a desire of better

Q: - What is your assessment of the level of required digital skills?

ITA: – the need for the raise in digital skills especially of the most vulnerable parts of our society is
highly required

Q: - Are there programs, projects, initiatives in the country in the field of developing digital skills of
citizens to use the eHealth systems?

ITA: – to MOIDPLHSA (not such program is run directly by ITA)

Q: - What are the main challenges/constraints in developing citizens' digital skills to use the eHealth
system?

ITA: – allegedly remoteness of some beneficiaries and in particular poverty, the access to the means
for the access of digital services (computational devices as well as internet connectivity)

Q: - What steps need to be taken to improve the digital skills of citizens to use the eHealth system in
the country?

ITA: – to MOIDPLHSA

10. International Cooperation, Projects, Initiatives

Q: - Are there any eHealth best practice exchange platforms available in the country?
ITA: – we tightly cooperate with WHO, EU, USA CDC, USAID, UNDP, UNICEF etc. with the aim to
get our hands on best available practice
Q: - Which initiatives / projects, that are being implemented or are in the process of implementation
under cooperation with EU level, could you single out as the most successful? why?

ITA: – existing cooperation mechanisms with EU eu4digital e.g. we would desire to have more tight
and intensive cooperation to get our hands on best European practice and ensure data
interoperability of our organizations.

Q: - List the most successful initiatives/projects/programs, from your point of view, in the EU;

ITA: - EU DCC

Q: - Which EU initiatives / projects / programs can be applied in the country? How?

ITA: – e.g. we would like to be part of united European prescription platform. The person who got
the prescription in Georgia, should be able to get the prescribed medicine in drug store in Vienna,
Brussels, Malmö and so on when travelling and vice versa.

Q: - Which EU institutions/organizations/bodies, in your opinion, should our country cooperate with

in order to develop the eHealth system?

ITA: - We think starting a sustainable Twinning project with selected EU state’s relevant authorities
would help a lot

Q: - What forms of cooperation should be used to interact with the listed institutions / organizations /
bodies?

ITA: – At ITA we think we need a direct dialogue with EUD in Georgia together with MOIDPLHSA

Respondent: Zviad Kirtava

 Professor, Program Coordinator of One-cycle Educational Program of Medical Doctor

at Caucasus Medicine and Healthcare School; Caucasus University.
 Healthcare Research Director, GeoCase, ThinkTank.
 Board Chairman, Partners for Health (PfH) NGO.

Format: in-depth online interview (Zoom)

Sh. J: - Tell us your opinion on eHealth Policy and Strategy in the country.
Z.K: - I do not think we have a policy or strategy. We had a fairly large, Healthy Georgia - Connected
To You in 2011.The document, which was excellent from the beginning, also covers the strategy and
all the other important issues. But since then 11 years have passed, many things have developed
significantly and this document also needs to change. The worst thing is that when we have strategic
document, then time passes, this document becomes obsolete and there is no discussion about what
we did, where we went, what stage we are for now, what we have changed or what has become
obsolete.

As for telemedicine, mobile telemedicine and interoperability, we are even worse off here, as Georgia
was one of the first to mention and briefly define the term "telemedicine" in the Law on Medical
Practice in 2000-2001. Nobody had it then, but 21 years have passed since then and we do not have a
legislative document, even if at least a resolution on this topic. There is a important law on electronic
health records, but on the other hand, I do not remember the document, especially on mobile
telemedicine or interoperability.

Sh. J: - It the current level of eHealth policy and strategy satisfactory?

Z.K: - Based on the above, it is not satisfactory. A good update is especially needed now, because
sometimes a very serious, catastrophic crisis creates the ideal conditions for something to develop,
and for telemedicine the covid-pandemic was a very good impetus. Not only with us, it happened in
America too, which was far ahead, but now the development of telemedicine got an amazing boost
because there was no other way, everyone was in isolation and whether they wanted it or not,
everyone had to switch to telemedicine. It needs to be used right now. However there is one
downside to this, Americans have always stood in such a way that despite liberal views, quite a lot is
regulated there, just like in the EU. And now in telemedicine, COVID has brought a situation where
there is no time for regulation, and a number of restrictions that were common to many there have
been lifted, at least temporarily.

But now we need to bring it in line with each other and, most importantly, develop a policy, because
a small country like us, with small resources, can not cover everything in this area, so something
should be prioritize and than the policy and strategy should be formed. We are now in a situation
where this document is both good and very bad. The good thing is that it is well written and a lot,
while the bad thing is that so much is written, it is difficult to just read and understand it, even just to
understand the terminology . So I think it would be good to translate or make an adapted version of
this document. Directions should be allocated and enforcement should be distributed to various
institutions, agencies and stakeholders.

Sh. J: - What is most important challenges in eHealth policy and strategy?

Z.K: - Like I said, the problem is first creating the document and then writing how we do progress. It
is also important to pay attention not only to what has happened to us, but also to what we have
failed to do, as this failure may have been such that it could be explained by subjective reasons and
subsequently planning will be improved. Or we may realize that this was not our business and we can
not overcome it and shift the focus to something else.

The policy now needs to gather a certain number of people, which would be good to have
representatives from the business sector as well (because this field has developed very quickly),
although they may not be willing / willing to develop this policy at all. The composition of the
ministries should also be determined, of course, the participation of the Ministry of Justice will be
necessary. Various organizations should also be involved, as well as find resources in the parliament.

We could have been further ahead in eHealth over the years, especially when even in 2011 we had
very good guidance for doing so. After that, it seems that this direction has not developed, although it
is not the fault of the Ministry of Health, because the biggest task since 2013 was to introduce
universal health care, plus the treatment of hepatitis C, and finally COVID. So there are objective
reasons and although eHealth is very important, other more priority issues had to be addressed.

Sh. J: - In your opinion what is ongoing eHealth priorities for eHealth governors?

Z.K: - As for the priorities of the direction itself, it is telemedicine, especially for primary health care
and especially for remote, mountainous or border regions (where even in winter we have serious
interruptions) and emergencies (a brilliant example of which was the prolonged Covid-Pandemic).

As well as mobile telemonitoring , this direction is for chronic diseases such as diabetes, neurological
diseases as well as for the elderly. In general, the leading direction of the whole eHealth in the EU is
focused on the elderly population. Understandably, the reason for this is that these countries are
aging, reaching 19-20% of the elderly, and most of them live alone, so life there has brought priority
to this direction. With us, this issue is not so acute, but still there is a large share of people living
alone and somehow we have to raise this issue. In addition, from a practical point of view, there are
far more resources invested in research and funding by the EU than in other programs.

Another very important issue is to remind these people: some have tests done once a month, some
need sugar control, some need to see a doctor periodically. Very simple systems for this can be
introduced and there is even an immunization calendar and so on. These people might prefer
someone to call them directly and remind them that way, however we need to encourage electronic
means and somehow involve the population in this.

Sh. J: - This might require large amount of funding, right?

Z.K: - Funding is always a problem, however even small funding is important.

Another important issue is cyber security. Generally, when patients have been emailed a reports /
health histories, it is certainly not good, too many leaks can happen this way. Insurance companies,
pharmaceutical firms are well regulated on this issue of privacy and cyber security because they know
it is dangerous and are careful. But if a common portal is to be made where all patient information is
uploaded, it is important to determine how that information will be protected from loss, for example.

Sh. J: - How eHealth is regulated?

Z.K: - On ePrescription there is a ministerial order and not a law, although there is no need for a law
in this regard, the order is sufficient.

As for telemedicine, mobile telemedicine and interoperability, I do not think there is any law, in
Georgia there is only internal interoperability regulated, cross-border interoperability is not here.

As for the protection of personal data, we also have this law. I think this is one of our strengths and
also personal data is one of the most important issues in the field of healthcare because there is a lot of
personal information here.

We also should have big data, but I do not know how usable it is. One side is that it is regulated and
the other is how we use it.

Sh. J: - Which are the main stakeholders in eHealth field?

Z.K: - Ministry of Health, NCDC, a separate health organizations, Ministry of Justice. Also Ministry
of Education, in the sense that health care is an important factor, especially in schools: a healthy
lifestyle, protection from trauma? protection from cyber-bullying. Also, there should be a doctor in
the school who will play the role of registrar. It will help us a lot, because the more this doctor has
access to share this information electronically, the better management of students’ health will be
possible. Also the Ministry of Economy and Sustainable Development could be involved.

Sh. J: - As for the development of telemedicine and mobile telemedicine,

Z.K: - On the one hand, non-governmental organizations should be involved, on the other hand,
those who have already developed it - "Redmedi" TBC Insurance, "Ekimo" Evex, i.e those systems
that have practical experience in this field and money they have.

Sh. J: - In your opinion what are the main challenges, problems, and deficiencies in E-health
governance –

Z.K: - Lack of cooperation. It is logical that when funding sources are scarce and competition is
increasing, it is difficult for competitors (such as large, monster corporations) to tell each other what's
better than one system over another, to reveal what they have won or lost. This would have created a
very efficient system, but competitors would not have provided such information to each other ,
which is somewhat understandable when this sector is so sharply focused on profit. This barrier can
be overcome by imposing some incentives.

Sh. J: - How E-health management should be organized –

Z.K: - First of all, it is important to determine what is important for the policy, what kind of strategy
we should have. There should probably be some council. There should be a structure that governs
and a governing board that will be independent in its reasoning and will have the authority to make
recommendations. You may also have the opportunity to periodically hire an independent expert for
surveys. The experience of the Baltic States can be shared in this matter.

Sh. J: - Is the state investing in research and development of e-health? –

Z.K: - As far as I know, there are no specific funds allocated for this, but it would be good to be not
only here, but also at the EU level.

Respondent: Salome Abashidze

 Head of clinical process digitalization department at EVEX medical holding.

Format: in-depth online interview (Zoom)

D. Ts.: Hello Mrs Salome and Mr Shota. Today`s meeting is held within the Eastern European
Partnership project regarding e-health and e-skills. As you have been informed, Mrs Salome, our
project is international, and Georgia (as a lead partner), Ukraine and Moldova are involved in it. Now
I want to introduce you to each other. Mrs Salome Abashidze represents Evex clinic and is a digital
technology department head. Mr Shota Jamburidze is a famous expert in e-health and is involved in
our project as a researcher. One of the essential activities of our project is an in-depth research on the
e-health system in Georgia involving legal frame study and literary review, and one of the crucial
components is an interview with stakeholders to identify ongoing processes in the system. For
instance, to what extent you are satisfied with e-health services in the country and whether it makes
your activities more accessible. Now, let`s listen to Shota Jamburidze, who will start interviewing.

Sh. J.: Nice to meet you, and thank you for the interview. We have questions in different directions,
starting with the e-health policy. Since you represent Evex and are involved in every system, you
may use various systems within different programs. Do you happen to know whether the e-health
development policy is consistent? Or, do you have information about the e-health strategy?

S. A.: I have been working in clinical direction at Evex hospitals for a long time. I am in charge of the
clinical process digitalization department. We try to have patients' profile health records and
digitalize clinical processes. Nobody has introduced their policy to us yet. The Ministry mainly
provides the information via a letter or e-mail, or they invite us to a meeting and introduce changes.
What the Ministry has done is program administering, and at a fundamental level. The Ministry has
not done anything regarding patient information recording. They have just started some work
regarding form No. 100. They mainly work in financial administration. We have integrated into the
direction of billing, form No. 100 service and e-prescriptions. We have started cooperation with
NCDC. They have statistical forms, which we have integrated into two big forms. We want to
continue this work to provide the statistics to them. These are the available services of the Ministry
(recipes, financial administering).

D. Ts. Do they have patient records?

S. A.: No, they do not have records, neither ambulatory nor stationary.
D. Ts. Do not they have form No. 100? I am not very well aware of the medical field. As I remember,
form No. 100 reflects my health current condition.
S. A.: Everybody should know the essence of this document. When you visit the doctor or leave the
hospital, and they give you form No. 100, it describes your current health status.
Sh. J.: You have mentioned that they invite you to the meetings at the Ministry. Do you have a
specific contact person there? Also, there have been some changes lately, and the Ministry has been
divided into departments. How do you communicate with them?
S. A.: Generally, in every private organization, including our clinic, staff members change their
workplace and may start working in the Ministry or vice versa. We have a specific person there.
When they make any legislative changes, they upload all this on the legislative herald. Our lawyer
gets acquainted with it, and we start finding out the news. Then this person gets in touch with the
Ministry; however, it is not a well-organized system, and the situation is a bit chaotic. We are more
active in this regard and contact the Ministry. For instance, yesterday, a change was made to the
legislation regarding medical documents. This ordinance regulates the procedures regarding filling in
the medical documentation and creating a patient`s portfolio. A change entered into the force a day
ago regarding e-prescription. They have their specific form for it. A doctor should register
on www.moh.gov.ge by his/her certificate number and should prescribe recipes there. We asked for
integration, and now, when a doctor writes a recipe, it is integrated automatically. A patient receives
the prescription via message. It worked in this way before, but a change was made in the ordinance
on March 1st. They require that a doctor write down the prescription number (consisting of 7
numbers) and copy it into three different documents (form No. 100, recipe given to the patient and
records) by hand. It complicates everything. Ten thousand doctors from 18 hospitals protested it. We
stopped the process and are working to solve this problem. I do not want doctors to write something
by hand. I want all this to happen automatically. We have a specific lawyer to let us know changes
promptly. We found out about this change in the morning and started getting information about this
change. The Ministry policy department made it. It is hard to find a person who initiates such
changes. Besides, it isn't easy to understand them correctly. The doctors protested this change.
D. Ts. You mean that the prescription number should be copied in the three documents mentioned
above by hand.
S. A.: Yes. Not only does this, a doctor makes an e-prescription in pdf format, and it not allow
him/her to copy the number. 
D. Ts.: So it should be written by hand, what complicates everything?
S. A.: Right, they must first write it down on paper and then copy it in those three documents. At
last, we managed to find the people who initiated the change. We explained the situation to them
that we synchronized the two systems. Then, we wrote an e-mail to them and asked for a meeting
with that person. All the process required quite a long time and much effort.
At last, we discovered that they had already had a meeting and talked about upcoming changes. They
have some mail groups, including the addresses of many people. However, it is not well-organized.
There may be addresses of EVEX clinic doctors as well, but if the information is not provided to the
head office, we may not find it out. They should reach out to people in a proper way. They should
inform us as users, and we should be able to prepare for changes. We even discovered that the change
was made because of the audit conclusion. So, they took this conclusion into account. Not only this,
the change went into force on March 1st, and they gave us a month to prepare for it. From April 1st,
they will start sanctions for not doing it.
D. Ts. : You have time to make them improve it.
S. A.: But policymakers should think well before taking decisions. When we phoned the Ministry,
nobody answered the phone, and at last, we had to get in touch with Mrs Tamar Gabunia (the
Minister's first deputy). When we get news, doctors protest and say that they will not do it. Yesterday
we had a meeting, and they got involved with management. The meeting participants asked them the
same questions. We discovered that there is some problem. There might have been some meetings,
but doctors might not have listened to the information carefully.
Sh. J.: When you asked for the meeting with a person from the technical direction, did you manage to
contact any of them?
S. A.: It took approximately a week. We sent e-mails to them and asked them questions but in vain.
They readdressed them to other departments, which could not answer our questions. Then we started
the process again. At last, a curator of this issue phoned me today, and we made everything clear. 
Sh. J.: Does the e-system have a curator?
S. A.: I think that she manages IT issues regarding the hospitals. Though I know her name (Mari
Gelashvili), I do not know her position exactly. The Ministry has many programs. They also have a
program on medicines, and this program was moved to a separate group. They created a service of
program medicines. We discovered that we do not have integration with these medicines. We have
integration with a general base. Our doctors have to enter www.moh.gov.ge and prescribe medicines
through it. I asked for integration, but they say they are not ready for it yet. Many clinics in Georgia
have access to their programs and servers. They asked us to write to them and request integration
into the program. We found it out by chance from the patient. We prescribed medicine provided by
the program, but it turned out that she could not get that medicine because of an incorrect recipe
number. We discovered that the Ministry had made some changes in this regard. There are many
such examples.
Sh. J.: Can you tell us which systems/programs you are integrated into the Ministry, NCDC, the Social
Service Agency and others?
D. Ts.: Do you have your soft? Can you tell us the program name in which you work?

S. A.: There is an IT company Vabaco, and it is their product. It includes a financial as well as a
clinical module. When we need some technical integration, Vabaco`s support team must contact the
Ministry to do a program integration. They are experienced in this regard. We are integrated into
EHR modules. It is the Ministry system, and we exchange information regarding form No. 100 and e-
prescriptions. We even process statistics, including billing, calculations, etc. I have just mentioned the
calculation module on purpose because they have announced that we have to provide this
information electronically, like in the case of form No. 100. We used to provide only pdf versions of
form No. 100 monthly before. We provide only 60% of the form No. 100 information electronically,
they do not require more, and it is partial and brief. It includes brief information, including diagnosis,
visit date, etc. But now they have announced that we have to provide calculations electronically.

D. Ts.: Did you have to provide paper-based calculations before?

S. A.: Yes, we did it once a month.

D. Ts.: Has an electronic module started?

S. A.: Not yet. They are planning to do it. They try to plan and consider this issue well because it is a
more complicated system. It has not started yet, and we have been involved in the process for a long
time and have time to prepare for it. Both parties should be technically well-prepared for the process,
and active talks are going on about the issue. If we are not integrated into the system, we cannot
exchange the information in another way.

Sh. J.: Which NCDC modules are you integrated into?

S. A.: There is form No. 025 (monthly statistical and ambulatory), and we also work on form No. 066.
The form is generated, and a person will download it and send it to them. Therefore, we do not have
to work on the NCDC portal. As for form No. 025, we do not have to download it and send it
automatically.

Sh. J.: Does billing information overlap calculation information?

S. A.: The process is interconnected. It is linked to service price, and calculations are processed in the
price dimension. Billing is a live and ongoing process, and it may involve over expenditures, factual
and non-factual expenses, specifying the form No. 100, etc. We provide this information once a
month to them, but they require providing it simultaneously from receiving a patient and giving a
specific code to him/her. We should calculate approximate expenses from receiving the patient, but it
is very hard since it is difficult to estimate what we may need during the treatment process. They
have been actively working on it for 8 months. However, I do not know at what stage they are now.

Sh. J.: Does a new LEPL of IT technologies manage it?

S. A.: Frankly speaking, I am not aware of it. As far as I know, different groups are involved in the
process, but they have not come to an agreement yet.

Sh. J.: What about cancer and tuberculosis screening modules?

S. A.: It is a bit complicated for us because they include cancer screening and immunization modules.

Sh. J.: You enter the information in your soft and NCDC modules. Did you do the same regarding the
Covid-19 vaccination?

S. A.: Yes, we did. We double entered the information. In the beginning, they told us to enter the
information only in their modules. Should I open the ambulatory card when I vaccinate a patient?
They tell us that it is unnecessary since s/he is not a patient. It is just considered a person who comes
to be vaccinated and then leaves the clinic, and we still argue about this issue. There is no regulating
act regarding it. It is impossible to open an ambulatory card for each patient when a doctor vaccinates
approximately 9000 patients a day, even if you enter brief information. The only thing they did was
an immunization questionnaire, which is the patient's consent. They told us to appoint a person
(nurse) who would fill in these blanks. But when I got vaccinated, the doctor was so tired that I filled
out the form myself. They asked to archive those blanks. Now we have many records of ambulatory
cards which are empty because the doctor does not fill in this card, and there is no protection
mechanism for me. If there is a new minister in two years and somebody checks all these blanks, they
will be empty.

As you know, we have to enter much information in blanks in case of flu vaccination and children's
vaccination, but as they say, they will not control us. The pandemics are over, but there is no written
record that they will not require clinics to open a medical card. If I ask them whether they will
charge us if we do not open medical cards, they will charge us. That's why we do not ask them and
initiate the question, but we are afraid at the same time.

Sh. J.: I think there will be no sanctions because it will be hard to implement. Hospitals were so busy
during the pandemics I do not think that anybody will charge you. I think nobody will have such an
idea.
S. A.: However, our risk management department says it is just an opinion and not a claim.
Sh. J.: Did you have to work in any other system or applications because of Covid-19?
 S. A.: Yes, we did. There were several directions. In one system, we had to enter the information
regarding the vaccine dose, type, etc. We also entered testing results on www.moh.gov.ge. We had to
upload information about testing our staff members (number of tested members, results, test type,
etc.). Since they provide testing materials to us, they need to calculate the number and type of user
tests and their results. Therefore, a separate module was created for test results. There was a heavy
workload, but now we are not so busy with vaccination. Moreover, we worked as Covid-19 clinics,
but we are not anymore, and consequently, we don`t have to do this stuff. 
Sh. J.: When you communicate with the Ministry or its LEPLs, do you have to use the services of e-
signature or e-stamping?
S. A.: You have tackled a very relevant issue because it is the biggest problem. There is no official
agreement regarding the valid e-signature. If you help us regarding this issue, we will be very
grateful. The previous minister was open and had good plans in this regard. There were meetings
with the Ministry of Justice, and we attended them. When you sign on a pad, it is considered valid.
But the process they offered to us was a bit complicated. According to their suggestion, doctors and
nurses needed their ID and ID readers for each person entering the system. It would not be rentable
for us. We were ready to invest and buy readers, but we would have to take all the doctors to the
House of Justice and make their signatures valid. But the process is very hard to administer.
Sh. J.: Is it the only way to have e-records to avoid stamps and so-called “wet signature”? 
S. A.: Many doctors in our hospitals used to work abroad and had to deal with different softs. When
we ask them how they made their identification, they say that they had the doctor`s certificate
number assigned by the Ministry. They entered the system using those numbers, and their signature
was valid. Therefore, a clinic may not invest in it since they know that this issue must be solved.
Sh. J.: Do you mean that it requires big money?

S. A.: We do 80% of the services electronically, print them, and doctors sign documents.

D. Ts.: Is acquiring an ID reader a problem for you?

S. A.: ID reader and administering (50/50). For instance, I have to make a record and prescribe
medicine for a patient, and 15 patients are waiting for me, and it requires much time from me.

D. Ts.: I can help you regarding the signature.

S. A.: You will help us a lot.

D. Ts.: The issue does not refer to the Ministry but a LEPL of the Ministry of Justice. They developed
e-signature.

S. A.: Our representatives met with the relevant representatives, as I know. But they said that if
validation was done via the Ministry of Justice, the documents with e-signature would have to be
uploaded to their base. But medical documentation contains confidential information, and we should
exchange documents with the Ministry of Justice and the Ministry of Health. So there are three
parties in this case.

D. Ts.: That`s right. It is a product of the Ministry of Justice, and they should find the solution.

S. A.: The previous minister was actively involved in this issue and was going to change something in
this regard. However, the process stopped. But let`s look at the other side of this process. It is an
additional routine for doctors and requires much time from them when they can do it faster on paper.
I always say that the medical field is not a banking sector, and we cannot put it into frames and
restrictions. You should adjust to the current situation.

D. Ts.: There should be some compromise and solution to this situation to simplify your activities.

S. A.: Mr David, if I have to connect the reader, it may take five minutes, and it is too much time
because they even complain when they have to wait to launch the program for 40 seconds.

D. Ts.: We will discuss this issue and let you know the possible solution.

S. A.: There is always a solution. We should try to find it.

Sh. J.: I will ask you the question regarding e-skills. Your network is quite extensive and employs
hundreds of doctors. How would you assess their e-skills? For instance, how doctors over fifty can
deal with it?

S. A.: The pandemics have contributed to developing e-skills to some extent. It is hard if a person is
over 70 (we have personnel at this age in the regions). Some of them even do not know how to
switch on the computer. They say that they will leave work if they are made to work in the system.
In ambulatories, many middle-aged doctors are involved in the insurance system. Due to the
insurance request for 10-15 years, they had to work in the system. I may not say that 50% of my
personnel does not work.

Sh. J.: What can you say about the situation in 2013 in this regard?

S. A.: If I suggested doctors work in Word in 2013 and fill in the blanks, they would protest it. For
the last several years, digitalization and everything around us has contributed to development in this
regard. Doctors are afraid of fines induced due to incorrectly filled-in documents. The Regulating
Agency has entered several clinics, checking the period of five years. I will not repeat abusive words
they (the Agency) tell doctors due to working in the system. We support doctors and explain that in 5
years, they will demand it from us. Such things should not be happening in the 21st century. I will
not specify, but we can provide the names of the Agency staff behaving so. They bully us.

Sh. J.: Do you provide training to your doctors (for instance, those working in the immunization
program)?

S. A.: We had online lessons about the system for doctors during the pandemics. Besides, there is a
trainer in every clinic who has to introduce e-module to the staff and provide technical support to
them, and it is a daily process at our clinics.

Sh. J.: Does the Ministry provide training on EHR or other modules?

S. A.: Yes, they do, but it has a meeting format. For instance, they may write that there is a training
on EHR module tomorrow and we should send the relevant people who will attend it. You have to go
to the training either in the Ministry or NCDC. The Ministry holds pieces of training in other cities as
well, but it is not systematic.

Sh. J.: To sum up, what are e-health challenges regarding the policy or practical implementation?
What are their solution and your recommendations?

S. A.: The biggest challenge is document formation ordinance regulating the process which was
written in 2009. You cannot adjust it to the present situation. The legislative base should be revised
because it is difficult for us to operate. They find out that after making amendments, they are not
reflected in laws. They should revise laws, adapt their e-services and help us instead of making
barriers. They should have a unified e-system. If they do not develop it, we will not make an
initiative. We have more e-resources than they may imagine.

Sh. J.: Systems are fragmented, and it complicates everything. You say that the legal frame is not
well-developed.

S. A.: That`s right. The issue of signatures belongs to a policy part, and something should be
simplified in this regard. Another big problem is administering medicines under special control. The
legal frame is very old, and unfortunately, we have to follow it. For instance, you have to underline it
in a red pen when prescribing drugs. In contrast, you do not have to do it regarding other medicines.

Sh. J.: When there was a program of psychical health, a relevant module was to be developed. Was it
developed and introduced? Are there any steps forward?

S. A.: It was so difficult to administer the process and that`s why we left it. However, we are in the
tuberculosis program. Tuberculosis and cancer programs are better developed and funded.

Sh. J.: You have an extensive network, and I will ask you about the internal systems. Do you work in
the same program in your clinics? Do you consider international standards regarding data exchange?

S. A.: Unfortunately, I am not competent in this issue, but I can involve a person who works in this
direction. Vabaco manages technical direction. We work in one system, and it has ambulatory and
stationary parts. We have 18 hospitals, and processes are fully launched in 13 of them. Covid-19 has
made some barriers to launching the system. For instance, we have not launched the system in
Kobuleti and Poti clinics since they were Covid hospitals. There was a lack of staff, and they were
very busy. However, the program is developed, and it is just copied to other clinics.

Sh. J.: Thank you for your comprehensive answers. They will be reflected in our study. The study
results will be represented at the meetings or round tables, and you will be invited to them.

S. A.: If a third party does not help us, we are alone in this battle. If there is more support, the system
will develop.
D. Ts.: As I have already mentioned, our project is aimed to identify the challenges and gaps in the e-
health sector in Georgia, provide recommendations and find solutions, and represent them to
policymakers. We will manage to do it via direct communication and planned events (round table
and international conference). We will help you with the advocacy of these issues. I had a
simultaneous meeting with one of the e-signature authors. Let`s arrange a meeting in Zoom next
week, and you can speak about the challenges. I hope that solutions can be found for them. Thank
you for providing interesting and essential information. It will be reflected in our study. We will
meet next week and continue active cooperation.

S. A.: We will get actively involved. Thank you!

Respondent: Temur Gaboshvili

 Head of the analytical and developing departments at AVERSI clinics.

Format: in-depth online interview (Zoom)

D. Ts.: Hello, I will introduce you to each other. Shota Jamburidze is our researcher studying e-health
issues. I also want to introduce Temur Gaboshvili representing the company Aversi. He will speak
about himself in detail. Thank you, Mr Temur, for your readiness and cooperation aimed at
interviewing our project stakeholders, and we are happy that you agreed to get involved in the
process. Now I want to allow our expert Shota Jamburidze to start the interview. Thank you for
selecting the questions because it will make it easier to talk about them.

Sh. J.: Hello, Mr Temur. The session is being recorded to prepare the transcript for our study. So,
please introduce yourself and say a few words about your position, duties and responsibilities in the
Aversi clinic.

T. G.: Hello, I am one of the Aversi group clinic representatives. Two clinics are united in this clinic
(New Life and National Centre of Surgery), and I am the head of the analytical department and the
soft. I supervised implementation of a new program in our clinics and integration with the Ministry
of Health (e.g. e-recipes and e-records), and I am aware of the issue. Before we start the interview, I
would say that I do not know your project, and it would be better if you introduced it to me.

D. Ts.: Our project is funded within the Eastern European Partnership Program funded by the EU,
and we – International Business and Economic Development Centre, are the project lead partners.
Our partners are Business Consulting Centre from Moldova and Economic Development Centre
(NGO in Lviv) from Ukraine. We started the project in December. The project lasts for a year, and it
is focused on e-health and developing e-skills in the Eastern Partnership Countries, and one of the
main activities is to conduct an in-depth study on e-health. We carry out this research in Georgia
while our partners conduct the study in their countries. Besides, at first, we developed a methodology
for the study. After finishing the study, we will have a round table with stakeholders, and we'll invite
them there too. We will discuss the research results. Your active inclusiveness will be necessary
there, and we will develop additional recommendations regarding e-health further development. We
plan to hold an international online conference in autumn where our partners will participate. Each
country will represent the study results. Besides, we will create a platform for e-health in all six
countries (Eastern European Partnership). This network will be representative. We have pretty
ambitious plans and want to follow them. Mr Shota will say a few words about the study, and then
we can start the interview.

Sh. J.: Our questionnaire was extensive, and it involved six issues regarding the policy, e-health
infrastructure, etc. Since you represent e-health system consumers, it is interesting to know whether
communicating with the national healthcare system is comfortable. What are the existing challenges,
and what should be improved? The research's first part covers healthcare policy. You have marked
the third part covering e-health infrastructure. Could you tell us who is responsible for developing e-
health policy and strategy throughout the country? Is there such a strategy?

T. G.: I am glad to participate in your study, but I don't quite understand why the western countries
are conducting it.

D. Ts.: Eastern Partnership involves six countries (Georgia, Ukraine, Moldova, Azerbaijan, Armenia
and Belarus) and their cooperation. EU has a neighborhood policy including these six countries.
Consequently, within these countries, the EU funds projects to improve e-health. We made a project
proposal to study the situation, develop recommendations, and provide them to the Ministry of
Health to improve it. We aim to make the system more comfortable for users and the private sector to
make it easier for users. Besides, we want to create a network in the Eastern Partnership countries.
The platform will contribute to communicating with governmental and private sectors, sharing ideas
and information, putting forward questions.

T. G.: As I see, there is no third party to evaluate the situation.

D. Ts.: Yes, since e-health is a novelty, it is natural that there is no third party to do it.

Sh. J.: We have been trying to integrate into the EU for fifteen years, and local legislation and policy
should be harmonized with their standards. Now we are implementing the project on e-health, but
there are different projects in different directions. The EU funds such projects to harmonize our laws
and standards with the European ones. Studies are conducted periodically, and through our research
we want to identify the progress in this direction. There is a network of e-health in the EU, and they
fund projects to identify progress or shortcomings. They thought that an unbiased study would be
necessary to assess the situation in Georgia. We will interview you, the Ministry of Health, the
Professional Union and other stakeholders.

D. Ts.: We will sum up all the process, evaluate the current situation and only after it we will develop
the recommendations. The first question is about the legislation and strategy of e-health. To what
extent are you aware of them? Are e-services easily accessible?

T. G.: I was mainly involved in the technological direction (program integration and data exchange).
As for the legislation, I would say that there are some gaps since healthcare requires data, including
the patients` personal information. Since it refers to the patient's health, we must provide the data.
They (the Ministry) are responsible for protecting the data. We share this information after agreeing
on it with the patient.

Sh. J.: In which of the Ministry projects are you involved?

T. G.: There are two e-projects (e-recipes and e-records). E-records include stationary services and
Covid-19 lab analysis, etc. I am involved in these two projects and try to fill the gaps in the system.
We actively tried to introduce the system in our clinic, have active communication with the
Ministry, and provided recommendations to them. For instance, they required the hemophilia
program patients` information provision in a standard mode, which was impossible. We
communicated with them, and after it, they changed the policy.

Sh. J.: With which department do you communicate? Policy, IT or other departments?

T. G.: At first, we communicated with the policy and IT departments. When we started integrating
the planned outpatient service a year ago, we communicated with the Ministry. We contact them via
e-mail, and they resend it to the relevant department. We wrote some remarks or recommendations,
and they replied to us. However, there have been some changes in the personnel, and some e-mails
were left unanswered.

D. Ts.: When did you get involved in these two projects?

T. G.: If I am not mistaken, I got involved in the e-recipe program in 2018, and the e-records program
was launched in 2019 in a test mode. A year later, we started to work on a planned outpatient check.
There is also a third project on providing calculations. However, the project initiator resigned, and it
was suspended. Could you tell me what you mean when you ask a question about convenience?

Sh. J.: Can you tell us whether it is convenient and comfortable to use the systems?

T. G.: Our clinic has a particular integrated registry program for e-records. We had the opportunity to
work in the Ministry e-system for a short time. We just found out the Ministry's requirements
regarding our program to integrate it. Particular forms were created where the data from our e-
system was collected. We provide the data to the Ministry in their requested format. As for
convenience, it was a novelty initially, but later they got used to it.
On the other hand, many clinics in Georgia do not have an e-registry system. Some of them may not
afford it, some may not have the willingness to introduce it, or it might not be necessary due to their
working process. We had several interviews and online conferences with the Ministry, which created
negative expectations. Because of small funding, the Ministry often had problems with the portal.
They were in a curious situation. For instance, they had a capacity problem on a hard disc. They
could not store the data on the server and had such a problem several times. The Ministry has a poor
budget, but I hope that something will change for the better after this intervention. I will be happy if
I am involved in the process more actively and become a team member.

D. Ts.: You have mentioned the program regarding the records and e-recipes. Could you tell us
whether its format and structure meet the requirements? Do these programs work well in your
reality?

T. G.: When I went to the clinic, we rented a program and paid a monthly fee as it is not our
property. We still cooperate with these developers. After that, we started to work on a new program.
E-records and e-recipes followed it.

D. Ts.: Is it possible to employ these programs in different ones?

T. G.: Yes, the clinic is free in its choice. The Ministry does not make restrictions. The Ministry had
its format and provided it to the clinic, and the soft had to be compatible with the format. For
instance, we have our program. The Evex clinic has its programmers and its administering program.
Others have their programs as well. However, some small outpatient clinics do not have such
programs.

D. Ts.: Do e-recipe and e-records need different soft/programs or not?

T. G.: One program is used for both of them, i.e. e-records and e-recipes are entered in the program,
and after it, they are sent to their addressees. The program meets the Ministry's requirements, and all
large clinics are involved. Clinics with significant turnover can't operate on the Ministry portal
without the program. It is possible to register on the Ministry portal, but it is much more difficult
since there is one user, and a doctor enters the portal via his/her user and password. However, in our
program doctor enters form No. 100, a nurse registers medicines used for the patient, etc. Whereas on
the Ministry portal, it happens by one user. I think it is difficult to do it in the case of a large clinic. It
might be appropriate for outpatient clinics and small ones in the regions. We may say that the
program meets the Ministry's requirements, and let's see what will be the following challenges.

D. Ts.: Is your program developed by Georgians or foreigners?

T. G.: It was developed by Soso Dzneladze, who worked as a programmer in the Ministry of Health.

D. Ts.: What is the program's name?

T. G.: It is called Web med, and it is much more convenient than the old program.
Sh. J.: Is it affordable to rent such a program? As I know, it is costly abroad.

T. G.: When our clinic decided to change the program, we discussed several program options. One of
them was a costly and not user-friendly German program. Another option was an Italian one. Both of
them were very expensive for Georgian reality. Eventually, they selected this program, which is not
as expensive as those.

Sh. J.: Within e-recipes and e-records, do you have to provide information about every patient or
only in specific cases?

T. G.: We are obliged to do it regarding each patient. It is reasoned by their aim to improve
healthcare and provide better service to people.

Sh. J.: You should be able to request e-records from them. If the patient revisits, you should be able to
ask for the record.

T. G.: But we do not require the records since they are stored in our e-system. The system allows the
doctor to get the patient illness history; however, the information is scarce, and it can't be efficient in
case of a specific illness. Therefore, it may help the doctor only to some extent. We use the
information left in our clinic. When a patient comes to our clinic s/he signs the relevant document. If
s/he is against it, the record is closed and blocked. As a rule, patients do not object since it is better for
them. It will help doctors 10-15 years later to treat patients, especially if they have chronic diseases.
For instance, a person may tell the doctor about symptoms, but it is more efficient to record all this
information in documents. However, the information offered by the Ministry is not enough. It would
be better if there were medical examination and analysis results. It would be helpful during the
treatment process. There was an additional point regarding it. Some clinics cooperate with the
program Medic integrating with their (clinics`) programs. It has an application and shows the
analysis results. It is very comfortable for the patient as well. The Ministry of Health has the same
system as well. E-health has a patient portal in the system, and patients can see the information about
their examination results there. However, if a patient goes to another clinic and asks the doctor to
find this information, it will not be detailed.

Sh. J.: Could you tell us the patients` portal name?

T. G.: You can go to www.moh.gov.ge, and on the left, there are windows, and one can go to e-
prescriptions and e-records via them. Doctors and patients can authorize and enter the portal.

Sh. J.: You have mentioned e-prescriptions and e-records, and you enter information on every
patient. Does it include primary and secondary outpatient care, specialized stationary services,
surgical activities, etc.? Also, while mentioning ambulatory, did you mean EHR ambulatory, or are
there other systems providing ambulatory cases?
T. G.: I mean EHR, but it involves patient's ambulatory visits and stationary treatment. The system
includes information on both treatment types.

Sh. J.: When you mentioned calculations, was it integrated into EHR or a particular program?

T. G.: It was to be integrated into EHR. However, it was not a final decision. We were on the stage of
technical work. It was considered to be the additional information to the treatment processes.

Sh. J.: Does your clinic use these programs within the universal healthcare program? Do you use
other systems for administering (e.g. reporting systems, case registration modules, etc.)?

T. G.: By switching to this new program, we were allowed to store data in databases. Unfortunately,
the previous program did not give us this opportunity since it was built on an outdated system. After
switching to a new program, we could process the data and use them in clinic analytics. In addition,
excel analytical functions have been improved. We could not use its analytical functions before as
they were not well-developed and restricted. Now we use SQR (database storing and administering
technology) and process data. In addition, there is an analytical program called Click, and we report
through it.

Sh. J.: As for the information provided to Universal Healthcare, I will share the screen and tell us if
you visit these portals.

T. G.: My team and I do not use them. However, a department in our clinic uses them because we are
obliged to do it by the Ministry. As I have mentioned, the calculation process is suspended, and we
provide their printed and scanned versions to the Ministry. The Ministry portal includes different
platforms. For instance, a performance platform provides information about the patient's visit time,
diagnosis, service provided to him/her, treatment type, funding, and relevant documents. Besides, the
Ministry requires to record the data, including radiological examination results (MRI, CT), on CDs.
We calculated based on the 2021 results and found out that it increases our expenses by 40 000 GEL.
Unfortunately, they (the Ministry) do not even explain why they require such staff from us. They just
request it from us.

Sh. J.: As I see, you send the information to EHR and this portal (ehealth.moh.gov.ge).

T. G.: We enter the information about the patient on the portal, including the financial one. As for
EHR, financial information is not uploaded there. As it seems, there is an internal communication
problem in the Ministry regarding the development of the projects. It is a bit complicated for me.
When I send the results of the radiological examination, why should I provide the same information
on the CD? The Ministry can require this information, and the clinic can provide it to them. In
several cases, their requests are absurd.

D. Ts.: Do you have to provide the results of every MRI or CT examination?

T. G.: No, they only require their beneficiaries` information. Nevertheless, we had 40 000 GEL extra
expenses a year.

D. Ts.: And how often do they require it?

T. G.: On the 15th day of each month, we should provide the report with the appropriate recorded
material on CDs. There might be some logic in this requirement, but I consider it a system gap.

D. Ts.: But you have mentioned that this information is uploaded on EHR, and is not this information
provided to the Ministry? Is not this information doubled?

T. G.: The doctor's medical conclusion is uploaded on EHR. There is no photo or video material.
There is no MRI or CT material since it is enormous in volume. If you record all the information on
one patient, you need one DVD. Besides, you need its reader which costs 15 000EUR.

D. Ts.: Such bureaucratic procedures make the healthcare system more complicated.

T. G.: It is hard to call it e-healthcare.

D. Ts.: It is an accounting issue.

T. G.: Yes, it is.

Sh. J.: Let's move to NCDC modules, e.g. C hepatitis module, immunization module, etc. Do you use
them? Are you integrated into them?

T. G.: NCDC has launched a separate platform, and now the data is uploaded there.

Sh. J.: And which portal is it?

T. G.: It is www.portal.ncdc.ge. We have a blood bank in the clinic, and donation is registered on this
portal.

Sh. J.: Are you integrated into this portal?

T. G.: No, we are not integrated. We had a discussion with their programmers about it, but they
refused because of limited resources. So, we did not have direct communication with them but
received such an answer from them. We have special staff for uploading the data on the portal. It is
not done by doctors but by administrative personnel.

Sh. J.: Do you upload this material every day?

T. G.: There are no restrictions, and we can do it daily. Last time, the information had to be uploaded
on the NCDC portal no later than three days after receiving the patient. There is form No. 025 and
form No. 066. Form No. 066 is for in-patient treatment cases and form No. 025 for outpatient
treatment. There was a restriction regarding them. There is also a Covid-19 lab, and they have their
deadlines for everything. However, there was no restriction on form No. 066 before.
Sh. J.: The same information is uploaded on EHR, case registration, and calculation.

T. G.: Yes, it is. For instance, Covid-19 analyses done at our clinic are sent there with the patient's
history.

Sh. J.: Do you provide Covid-19 analysis to EHR as well?

T. G.: Yes, we do.

Sh. J.: You have mentioned Covid-19, and what kind of information do you upload there?

T. G.: We upload the analysis time and the result (positive or negative).

Sh. J.: What are other obligations of the clinic regarding the Covid-19? Are the patients` information
sent separately, or is there a particular protocol/procedure?

T. G.: They are ordinary patients. When they come to our clinic, standard analysis is done, and the
result is uploaded on the portal.

Sh. J.: Do healthcare or your systems have any links to egovernment.gov.ge?

T. G.: No, our clinic does not have any connection to it.

Sh. J.: Are electronic ID cards used by patients or clinics? Do you use state e-services; I mean
electronic signatures.

T. G.: The issue was discussed, but mainly older people visit our hospital. Young people who come to
the clinic may not have an ID passcode or older version. Now we are going to develop a project to
involve our doctors and allow them to sign documents with ID cards.

Sh. J.: Is it your initiative?

T. G.: Yes, it is our initiative. We had a communication with the Ministry regarding e-signatures on
pads. However, the Ministry does not acknowledge such signatures, and we failed to implement this
project. I may say that it would be the most comfortable way for the patients. The technology would
be easy to introduce, and it would be convenient for the patients. Unfortunately, they rejected our
suggestion. They only recognize signatures by ID cards, but we refrained from it regarding the
patients. We are going to develop the project regarding doctors and administration. Let's see.

Sh. J.: What is its purpose? Do you want to save records electronically and not their printed versions?

T. G.: Yes, it is one of our main aims.

Sh. J.: Does it have legal grounds?

T. G.: There is relevant legislation, but they require signing documents by hand or signature by ID
cards under the Ministry ordinances. Although banks and many public institutions use signatures on
pads, the Ministry refrains from it since it refers to people's health. Moreover, I think that it will lose
its topicality since many new technologies are introduced. For instance, there are webcams in every
room, and it is impossible to hide something. Let's see. Vision will change, and it will lead to different
changes as well.

Sh. J.: There was a question on integration and standards. When you integrate your systems with the
Ministry systems, do you need to match any particular standards while providing the data? For
example, there is EHR7, cda and some other standards. Do you use these standards?

T. G.: I do not know this standard well, but since the Ministry is an initiator, it provides a specific
form to us. We know what kind of information to provide and in what sequence, and our program
provides the information following it. All the mentioned standards will be involved there. We cannot
avoid these formats.

Sh. J.: Since you employ electronic systems in clinics that store extensive information about patients,
are there any particular directions from the Ministry regarding the storage timeframe?

T. G.: There is a special ordinance about it, and there are specific deadlines for storing stationery and
ambulatory records.

Sh. J.: Are there any special regulations regarding electronic storage?

T. G.: There is no special regulation regarding the electronic storage timeframe, but I suppose they
will include it in the particular format. There might be a person encoding. We will require it. It is
interesting to identify the clinic's efficiency.

Sh. J.: Let's sum up our interview. What do you consider e-health challenges, and how can they be
solved?

T. G.: The situation is much better regarding e-health than healthcare and its budgeting. I have
already mentioned existing challenges, such as hard disc capacity, which were solved. However,
possible challenges should be considered in advance. I'm not aware of their existing problems. The
working process goes without any impediments. It would be good if they integrated the NCDC portal
with our Webmed portal since separate data are exchanged and provided to them. It would be better
if they were integrated into each other. Unfortunately, the patients have no benefits since the project
is new and information needs to be accumulated to become practical.

Nevertheless, the idea is excellent, and I am happy that such a project has been implemented in our
country. Let's see. I am happy to see the third party as an evaluator in this regard. Unbiased
assessment is critical, and it will be good if the Ministry considers suggestions. I will be happy if I am
involved in the working process. I am ready to cooperate with you at any time.
Sh. J.: Thank you for the provided information. We will include it in our study, and it will be sent to
the Ministry as well. In addition, we will invite the Ministry representatives to every conference or
round table meeting. We will inform you regarding the upcoming events as well.

D. Ts.: Thank you, Mr Temur, for the interview. The provided information is precious to us. Since
you employ these electronic services, your information is unbiased, practical, and valuable. We, as an
independent party, will evaluate it objectively. We will also interview other respondents from your
field and the policymakers from the Ministry. We will draw a conclusion and write down findings
and suggestions. The next stage will be a round table, where we will invite all these people, including
policy and decision-makers, and discuss everyday problems you face and the ways of their solutions.
Although they know the field challenges and barriers, they will see them more apparently there.
Through the mutual discussions, you will find ways out. This is our primary purpose and motivation.

T. G.: Unfortunately, many members of the implementing team have left the Ministry. Maybe
because of different opinions. Unfortunately, it became difficult to communicate with them, and I
think that a round table with the third party will be productive and efficient if they listen to our
opinions.

D. Ts.: They will listen to you. That's why we are holding this meeting. Thank you for the interview
and provided information. I wish you peace and good health. Goodbye.

T. G.: Thank you! Bye.

Respondent: Irakli Sasania

 Managing Partner in My Doc Teleclinic.

Format: in-depth online interview (Zoom)

Shota Jamburidze: Please introduce yourself (name, surname, company, position) and say a few words
about your relation to e-health.

Irakli Sasania: Hello, I am Irakli Sasania and I represent My Doc Teleclinic and I am its managing
partner. The company covers various directions of e-health, including a medical portal. It (portal)
uses different diagnostic means, including artificial intelligence, to provide tele medical consultations.
The portal is created to improve the communication between a doctor and a patient. It has also been
introduced as an application. The portal allows us to collect all the information regarding the patient
in one folder so that s/he can use it during the subsequent visits. Our company aims to provide the
population with medical services. Nowadays, modern medical technologies such as Point of Care
Devices allow people have diagnostic devices at home. We work on such issues and try to collect
patient data at once, save them, and provide them to the relevant medical staff. We try to include
many diagnostic means based on artificial intelligence.

Sh. J.: As I remember, in 2017 or 2018, you represented the site My Doc where you indicate the
symptoms, and it helps diagnose a patient.

I. S.: Furthermore, after listing the possible diagnosis, the program allows the patient to contact the
specialist and make an appointment. It may be either a teleconsultation or a face-to-face visit to the
doctor. It depends on a doctor's decision. It may be done through this platform. Besides, the patient
can pay money via the application as well. Not only this, what is the most important, the patient and
the doctor stay in touch in follow up mode. The program can remind the patient about the coming
check-up, etc.

Sh. J.: Since the program is so diverse, you should be aware of the state policy and regulations in this
direction. Is there any united national healthcare policy or strategy, or does the Ministry of Health
identify any priority directions?

I. S.: Unfortunately, there are not. E-health is relatively new, and there is no common definition of
this term in Europe yet. Its rapid development may be the reason for it. Unfortunately, there is no
vision or strategy. Although they say that the healthcare system should become electronic, it is hard
to say what it should involve. E-health includes e-records and general information about a health
condition, artificial intelligence, telemedicine or tele healthcare. It is a vast field, and it needs a
detailed description of what to include. We should identify what we call e-Health and what we mean
by this term. I think that the policy and strategy should be developed according to it. I have not seen
a common vision yet.

Sh. J.: Is there the same situation regarding telemedicine and mobile medicine?

I. S.: Unfortunately, I have not seen any document like this. Maybe it is good since it will contribute
to its fast development. Although there are some steps forward regarding e-Health development, they
only refer to one point (e-records). Telemedicine has also developed. However, these were phone
calls, and Covid-19 contributed to it. Now, doctors should switch to using e-recipe. However, there is
no clear outline of what e-Health should include and what should we develop.

Sh. J.: To your mind, what are the main barriers regarding the e-Health policy?

I. S.: I think there are some of them. There are some studies regarding it (Why is it introduced? What
are the main barriers in Europe?). The reviews have shown some political barriers rather than
financial or other obstacles. There must be political will to take the decision and show that it is a
priority issue. The decision-makers should realize its importance as it improves healthcare and its
financial situation. The second is openness and readiness to receive changes. Medical staff can do it
with difficulties since they have to switch to a new system, get to know new technologies and very
often, it causes resistance to novelties. The third barrier may be radical redesign since you have to
change many things completely when you want to switch to a new system. As it seems, there is no
readiness for it in Georgia. They are afraid and are not ready to do it. 85% of the medical institutions
in Georgia are private, and it is hard to unify them in one system to have unified e-records.
Generally, medical data are not standard, and it may be one of the several barriers. Vision and will to
introduce it soon is very important in this case.

Sh. J.: Is there any agency in Georgia which should manage this process? Who should be involved in
policymaking?

I. S.: A new department in the Ministry of Healthcare should manage this process. I think there
should be a consulting group which would develop a strategy, and there should be a state agency
which should implement it. However, I wish the agency was representative (i.e. it should involve
state and private institutions` representatives).

Sh. J.: You have mentioned that private non-standard softs are used as well. There is no standard in
the country, and it creates problems regarding interoperability (exchanging the data) and integration
with the Ministry of Health. Do you think that there is a common approach or frame?

I. S.: You know that there is no such approach, unfortunately. Since the data are not integrated,
folders and personal data are lost, and specific data may be available for some people. Protecting
personal information is another problem regarding e-Health. Unfortunately, nobody works to
introduce a common standard required by Europe, and it is one of the severe problems.

Sh. J.: Since the information regarding the patient is specific, to what extent is it protected in
different softs as it should be done in case of particular data? Does anybody control protecting the
data?

I. S.: It must be controlled, and there is a particular institution. However, I am not aware of their
criteria. I know several hospitals where the patient personal data is available to anybody. When we
were developing the app and collaborated with Google, we underwent serious procedures regarding
personal data protection. I doubt whether personal data are protected in any of those private softs. I
do not know whether they are controlled or not.

Sh. J.: As I know, none of them has been fined yet because of it. Which of the state systems would
you emphasize? What benefits do they have?

I. S.: I would emphasize EHR, the e-recipe system. It has public healthcare benefits since big data are
collected and can be processed. However, there is one drawback, since the data are not standard, it is
hard to say whether they are credible or not.

Sh. J.: What can you say about the development of these systems? For instance, there are module and
registry systems, EHR, etc. What can the Ministry do to unify them or create a new system?
I. S.: What we see at the given moment is just registration and data collection. It is necessary to
standardize data to make them credible. Besides, the system should allow saving photo and video
materials (e.g. angiography or cardiograph materials) to make the patient information complete. It
also should allow reporting and making statistics, and it should be done automatically. It should
automatically make statistics based on the reasons for death and range hospitals according to it. I wish
there were more diagnostic means, standards, and protocols to help doctors make decisions. For
instance, a system based on artificial intelligence evaluates the symptoms, etc.

Sh. J.: Are the protocols shared via e-format? Are they provided to doctors? Is it introduced?

I. S.: There are guidelines and protocols (so-called algorithms) for doctors. For instance, an algorithm
shows that a doctor should control pressure if a patient has a headache. In case of pressure, the
algorithm prompts the doctor the following steps according to the initial symptoms. There are such
means worldwide. There are some guidelines in Georgia, but they are enormous by volume, and
nobody will read them, especially their e-versions. These should be algorithms with quick decisions,
and many companies are working on them.

Sh. J.: Have you communicated with the Ministry of Health or the Ministry of Justice regarding
integrating or accessing personal information?

I. S.: We have not talked about it yet, but they told me there would not be any problems in case of
necessity.

Sh. J.: Your platform is the innovative one, and does the state support innovations in the e-health
field? Is there any particular fund for it or investing mechanism?

I. S.: GITA supports start-up companies regarding innovations. It also funds a good business project,
and the co-financing fund gets involved in the process.

Sh. J.: Does the Ministry of Health have any special funds to finance studies or innovations in e-
health?

I. S.: I do not know whether the Ministry has such a fund or not, but I know that UNICEF, Caritas,
the Israeli Embassy and others work in the e-health direction and are going to implement some
projects. However, I do not know whether it is funded or not.

D. Ts.: You have just mentioned the projects, and GITA is one of the effective mechanisms for
funding innovations and start-ups in Georgia. As a private company, I would like to know if you have
tried Horizon 2020? Have you made any project proposals for them?

I. S.: No, we have not tried.

D. Ts.: It is a perfect way to obtain funding. It is aimed to fund NGOs and private companies, and it is
one of the advantages of this competition. However, you should be in a solid consortium to receive
funding since one of the evaluating criteria is partner assessment (How strong are they? Who are
they? What is their background? etc.). As project budgets are impressive (5, 10, 20 million), it isn't
easy to compete, but still, there are some chances to receive funding. Georgia has been its member
since 2017, and this year, after updating the program, Georgia is still a full member. When they
announce a call, I will let you know, and you can apply.

I. S.: With great pleasure. We also are working on mobile health. We have relevantly equipped
minibuses, and they go to different villages and checkup patients there, and they contact doctors
from there.

Sh. J.: What kind of testing do they provide?

I. S.: Based on the artificial intelligence and symptoms, we diagnose patients, take down blood
pressure and pulse, take a cardiogram, measure sugar level and cholesterol, and examine lungs using
the stethoscope based on the artificial intelligence. A doctor sees all data electronically at once. And
after finishing the check-up, s/he (doctor) advises the patient on what to do. It is the first case of
tele/video medicine in Georgia.

Sh. J.: Are there any regulations regarding it (i.e. how these consultations should be done?).

I. S.: No, there are not. However, there should be some standards of conduct and ethical norms. Since
it is not a face-to-face communication, there should be some norms about consultation duration, type
of a decision, in what case to ask the patient to have a face-to-face visit, etc.

Sh. J.: You might have met with different clinics and patients, and what can you say about e skills?
Do people (doctors and patients) have the necessary skills in this direction to benefit from e-health?

I. S.: It needs radical change; I mean e-health formalization. On the one hand, the policy and strategy
of e-health should be developed, but on the other hand, the state should manage its implementation.
And it is impossible to do without intensive training of medical staff and patients as well. So I think
that it should be promoted and encouraged by providing some discounts in case of registering there.
So I think that it will contribute to its start.

Sh. J.: Do you happen to know if any training series are provided to doctors and patients to make e-
health easier for them?

I. S.: I think that it has a local character. There were several meetings, and different organizations also
held interesting webinars.

Sh. J.: To sum up, could you tell us the main challenges and recommendations to improve e-health
throughout the country?
I. S.: The main challenge is that it is necessary to have a clear vision and systematic approach to this
issue. Actions taken should be coordinated as well. Besides, there should be some way to stimulate
private and state providers.

Sh. J.: Thank you so much for the interview, Mr Irakli.

D. Ts.: I should say that there is no country where e-health covers everything since it is a novelty.
But still, which countries would you emphasize as leaders in this field (top three countries)?

I. S.: By the way, China is on the advanced level in this regard. In the USA, it is very well developed.
Though not every organization is involved in the system, they work hard to develop a common
standard. China has excellent results in this regard. National Health Service is very well organized in
England as well. Norway, Finland, Scandinavia and Sweden also have good results in telemedicine.
EU works hard to establish a common standard in Europe in this regard. Besides, they study the
situation in Eastern European counties.

D. Ts.: Thank you for an exciting discussion and the information provided. It is essential for our
study. It will help us identify and see the general situation, challenges, the ways of their solution and
recommendations. As soon as we finish, we will have a draft version of the study. In June, we will
hold a round table with stakeholders, policymakers, experts and scientists. We will present the study
and then listen to your opinion, recommendations and suggestions to identify an actual situation
regarding e-health. Thank you so much!