Black Book survey finds overwhelming support for reform, but says vendors must lift audit, exception handling and reporting capabilities.
Australian healthcare providers overwhelmingly support the federal government’s share by default reforms for pathology and diagnostic imaging – in effect from today – but many believe software vendors remain the biggest obstacle to a safe and successful rollout, according to a new industry report.
The Black Book Market Research report – Australia Share-by-Default Readiness 2026 – found almost universal support for the policy itself, with “99% of surveyed providers agreeing share by default would improve care coordination, reduce information gaps or support safer consumer access”.
However, “92% reported significant readiness gaps” in vendor workflows, audit trails, exception handling and monitoring systems.
The report concluded that while the policy direction enjoyed broad backing, “support for the policy does not equate to confidence in operational readiness”, with respondents expressing concern that many organisations remained dependent on vendors to deliver critical functionality before the reforms are fully embedded.
Black Book gave Australia’s overall share by default readiness a score of “67 out of 100”, with the weakest area being “exception handling and auditability”, which scored just 54.
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The report said providers were increasingly focused on practical implementation issues rather than the policy itself.
“Healthcare organisations are moving from trust-based vendor relationships to evidence-based readiness validation,” the report said.
According to the survey, 91% of respondents identified vendor clarity around readiness as their biggest implementation risk, while only 18% said they had tested reporting, exception management or upload failure workflows before implementation.
The findings suggested providers were becoming increasingly demanding of software suppliers.
The report found “98% wanted written evidence of vendor readiness before renewing contracts”, while “67% said they would consider replacing a vendor unable to demonstrate share by default readiness”.
Black Book said the reforms were reshaping purchasing decisions beyond the immediate implementation period.
“My Health Record readiness is rapidly becoming a procurement differentiator rather than simply a compliance requirement,” the report said, predicting it would become “a procurement gatekeeper by 2027”.
The report also highlighted concerns about how organisations would manage exceptions, including patients who opted out, sensitive diagnostic information and failed uploads, warning that those areas remained substantially less mature than basic upload capability.
A follow-up survey of respondents also found a degree of caution about the first year of implementation, with 62% saying they believed share by default was more likely to become a “compliance trap” than a clinical safety breakthrough unless vendors improved operational support.
Despite those concerns, the report concluded that support for the reform itself remained strong, with providers viewing share by default as an important step towards better-connected care – provided the underlying software and governance arrangements kept keep pace.
The Medical Republic sought comment from both the Department of Health, Disability and Ageing and the Australian Digital Health Agency, but did not hear back before deadline.
Read the full report here.
