This proposal may at firs glance appear somewhat controversial.  Open Healthcare is a concept inspired by "open banking," particularly initiatives like PSD2 (Payment Services Directive 2) in the European Union. The idea is to apply similar principles—data portability, interoperability, and secure third-party access—to the healthcare sector. Here's a breakdown of what it involves and the implications of applying a PSD2-like policy to healthcare.

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What is Open Healthcare?

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Open Healthcare refers to a system where:

• Patients own and control their health data.

• Healthcare providers, insurers (in the case of the US), and third-party digital health services can securely access and share data (with patient consent).

• APIs (Application Programming Interfaces) allow interoperability between different healthcare systems, much like open banking APIs allow apps to interact with banks.

It emphasizes transparency, innovation, and patient-centric care.

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What PSD2 Did in Banking (Simplified)

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PSD2 required banks to:

• Open access to customer account data (with consent) to licensed third-party providers (TPPs).

• Improve security (via Strong Customer Authentication - SCA).

• Foster competition and innovation in financial services.

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If Government Applies PSD2-like Policy to Healthcare

This would involve:

• Mandating standardized APIs for health data access.

• Allowing certified third-party apps (e.g., EHR's, fitness apps, telehealth platforms, AI diagnostics tools) to access patient records—with consent.

• Defining security and privacy standards akin to GDPR/SCA.

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Potential Benefits

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1. Empowered Patients

• Full control over personal health data.

• Easier access to medical history, test results, and prescriptions.

• Portability across providers (e.g., when changing doctors or hospitals).

 

2. Improved Innovation

• New apps and startups can develop solutions (e.g., AI diagnostics, personalized medicine).

• Integration with wearables, remote monitoring, and telehealth platforms.

 

3. Interoperability

• Different systems (public hospitals/ NHS, private hospitals and clinics, labs, pharmacies) can “talk” to each other.

• Reduces duplication (e.g., repeated tests), saves time and cost.

 

4. Better Outcomes & Efficiency

• Providers have full, real-time picture of a patient’s medical history.

• Enables predictive analytics, early intervention, and coordinated care.

 

Potential Disadvantages and Challenges

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1. Privacy & Security Risks

• Increased data flow can lead to breaches if systems aren’t well secured.

• Risk of unauthorized third-party access or misuse of sensitive data.

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2. Compliance Burden

• Hospitals and providers may need expensive IT overhauls to comply.

• Smaller providers may struggle with technical standards and costs.

 

3. Trust Issues

• Patients may be reluctant to share data with private firms.

• Fear of data being used for advertising, insurance discrimination, etc.

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4. Fragmentation Risk

• Without universal standards and governance, multiple competing systems can emerge.

• Inconsistent implementation across regions or providers.

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5.   Privatisation by Stealth

• Patients might perceive Open Healthcare as "privatisation by stealth" because while the concept emphasizes data sharing and patient control,

• it also opens the door for private, often for-profit third-party companies—including tech firms, insurance companies, and digital health startups—to access and use health data.

• However, could open the door to other opportunities for both the public sector, NHS and private hospitals and companies to deliver a more holistic health experience to patients, based on 'Well-Care', focusing on the areas of Prevention, population health, and rehabilitation.

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6. Competition

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• The existence of 'Open Healthcare' would  further fuel competition, and digital health innovation, evolving into a mighty, or mightier 'HealthTech' industry, along the lines of innovations seen to date in the Financial Tech, or Fintech industry, which is estimated to be worth approximately £209.7 Bn currently, globally. 

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7.    Implications for Clinical Workforce

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• Doctors particularly may deem laws legislating Open Healthcare a risk to workforce, fearing they may only further exacerbate the shortages for doctors, that are currently being experienced by both the primary and secondary care sectors. 

• The existence of Open Healthcare could provide an alternative highly lucrative source of alternative employment  for doctors in the private sector. 

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Example: EU’s EHDS (European Health Data Space)

We can see an instance of this if we look across to Europe.  The EU has recently adopted a new law to improve cross border access to health data within the EU. The new regulation which came into force in January 2025, is already moving in this direction with EHDS—legislation that echoes PSD2 principles, aiming to:

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• Let citizens access and control their health data.

• Enable data use across borders.

• Create a framework for health data sharing for research, innovation, and policy-making.

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Conclusion​

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Implementing an “Open Healthcare” model inspired by PSD2 can revolutionize care—making it more patient-centric, efficient, and innovative. But it must be carefully designed to balance access, security, trust, and equity.

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