Changes to requirements for upload of Pathology results via My Health Record

We want to tell you about some changes that are projected to come into effect over the next 6 – 12 months.

The Australian Digital Health Agency has been working to implement a “Better and Faster Access to health information” program, or “share by default” program.

A key component of this initiative is to increase access to diagnostic test results (including pathology and diagnostic imaging reports), through rapid upload to My Health Record (MHR): https://www.health.gov.au/our-work/modernising-my-health-record-improved-sharing-of-pathology-and-diagnostic-imaging-information

In May 2025, a decision was taken to make all pathology results, including genetic test results, available in the MHR either immediately or within 5 days of the result being available in the laboratory.

There are several steps needed before this decision will become a “requirement” and enforceable. The regulatory framework has not been finalised and there is expected to be a grace period once the legislation fully comes into effect.

Since the HGSA learnt about the decision to include genetic test results in the “share by default” arrangements, we have been liaising directly with the Australian Digital Health Agency (ADHA), Genomics Australia, and patient advocacy groups (the GUARD collaborative (GSNV, GAA and Swan Australia) and Inherited Cancers Australia) to highlight our concerns about how this change can be safely managed within current clinical and laboratory practices and resources.

Several conversations have occurred highlighting concerns for patient safety and the challenges with result interpretation. As a result, the legislation underpinning this program includes a number of exceptions to the requirement to upload results including:

• The consumer does not have a My Health Record.
• The consumer requests that the information is not uploaded to their record.
• A consumer’s authorised or nominated representative requests that the information is not uploaded.
• A healthcare provider reasonably believes that the information should not be uploaded because of concern for the health, safety or wellbeing of the consumer.
• The information cannot be shared due to circumstances outside the reasonable control of the provider, such as technical system issues that prevent uploads from happening.

There will be a “soft launch” of uploading pathology test results “by default” from 9 October 2025 involving this list of tests. The “requirement” to upload results has not commenced.

HGSA has been advised that we will see an exposure draft of these rules/ regulations creating the requirements, which are not due to be available until early 2026. There are expected to be slightly different obligations for different laboratory / testing entities.

HGSA is continuing to work cooperatively with the ADHA, GUARD Collaborative and Inherited Cancers Australia to explore ways to safely implement this measure. ADHA is interested in understanding more about the patient journey and case examples of how this initiative may be impact our sector.

HGSA CEO, Julia Mansour, has been invited to sit on the ADHA National Clinical Governance Committee and will receive regular updates on the progress of the program.

Further information is available here: https://www.digitalhealth.gov.au/healthcare-providers/initiatives-and-programs/better-and-faster-access-to-health-information