NHS Digital Data Release Register - reformatted

NHS Hertfordshire And West Essex Icb - 06k projects

5 data files in total were disseminated unsafely (information about files used safely is missing for TRE/"system access" projects).


DSfC - NHS East and North Hertfordshire CCG - IV & Comm — DARS-NIC-55679-K9X4J

Opt outs honoured: N, Y, No - data flow is not identifiable, Yes - patient objections upheld, No - DSfC for Invoice Validation Purposes, Anonymised - ICO Code Compliant, Identifiable (Section 251, Section 251 NHS Act 2006, Mixture of confidential data flow(s) with support under section 251 NHS Act 2006 and non-confidential data flow(s))

Legal basis: Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), Section 251 approval is in place for the flow of identifiable data, National Health Service Act 2006 - s251 - 'Control of patient information'. , Health and Social Care Act 2012 - s261 - 'Other dissemination of information', Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 – s261(7); National Health Service Act 2006 - s251 - 'Control of patient information'., Health and Social Care Act 2012 – s261(2)(b)(ii)

Purposes: No (Clinical Commissioning Group (CCG), Sub ICB Location)

Sensitive: Sensitive, and Non Sensitive, and Non-Sensitive

When:DSA runs 2019-10-01 — 2022-09-30 2018.06 — 2021.04.

Access method: Frequent adhoc flow, Frequent Adhoc Flow, One-Off

Data-controller type: NHS EAST AND NORTH HERTFORDSHIRE CCG, NHS HERTFORDSHIRE AND WEST ESSEX ICB - 06K

Sublicensing allowed: No

Datasets:

  1. Acute-Local Provider Flows
  2. Ambulance-Local Provider Flows
  3. Children and Young People Health
  4. Community Services Data Set
  5. Community-Local Provider Flows
  6. Demand for Service-Local Provider Flows
  7. Diagnostic Imaging Dataset
  8. Diagnostic Services-Local Provider Flows
  9. Emergency Care-Local Provider Flows
  10. Experience, Quality and Outcomes-Local Provider Flows
  11. Improving Access to Psychological Therapies Data Set
  12. Maternity Services Data Set
  13. Mental Health and Learning Disabilities Data Set
  14. Mental Health Minimum Data Set
  15. Mental Health Services Data Set
  16. Mental Health-Local Provider Flows
  17. National Cancer Waiting Times Monitoring DataSet (CWT)
  18. Other Not Elsewhere Classified (NEC)-Local Provider Flows
  19. Population Data-Local Provider Flows
  20. Public Health and Screening Services-Local Provider Flows
  21. SUS for Commissioners
  22. Primary Care Services-Local Provider Flows
  23. Civil Registration - Births
  24. Civil Registration - Deaths
  25. National Diabetes Audit
  26. Patient Reported Outcome Measures
  27. e-Referral Service for Commissioning
  28. Personal Demographic Service
  29. Summary Hospital-level Mortality Indicator
  30. Medicines dispensed in Primary Care (NHSBSA data)
  31. National Cancer Waiting Times Monitoring DataSet (NCWTMDS)
  32. Improving Access to Psychological Therapies Data Set_v1.5

Objectives:

Invoice Validation

Invoice Validation is part of a process by which providers of care or services get paid for the work they do.
Invoices are submitted to the Clinical Commissioning Group (CCG) so they are able to ensure that the activity claimed for each patient is their responsibility. This is done by processing and analysing Secondary User Services (SUS+) data, which is received into a secure Controlled Environment for Finance (CEfF). The SUS+ data is identifiable at the level of NHS number. The NHS number is only used to confirm the accuracy of backing-data sets and will not be used further.

Invoice Validation with be conducted by NHS East and North Hertfordshire CCG
The CCG are advised by the CEfF whether payment for invoices can be made or not.


Commissioning

To use pseudonymised data to provide intelligence to support the commissioning of health services. The data (containing both clinical and financial information) is analysed so that health care provision can be planned to support the needs of the population within the CCG area.
The CCGs commission services from a range of providers covering a wide array of services. Each of the data flow categories requested supports the commissioned activity of one or more providers.
The following pseudonymised datasets are required to provide intelligence to support commissioning of health services:
- Secondary Uses Service (SUS+)
- Local Provider Flows
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
- Mental Health Minimum Data Set (MHMDS)
- Mental Health Learning Disability Data Set (MHLDDS)
- Mental Health Services Data Set (MHSDS)
- Maternity Services Data Set (MSDS)
- Improving Access to Psychological Therapy (IAPT)
- Child and Young People Health Service (CYPHS)
- Community Services Data Set (CSDS)
- Diagnostic Imaging Data Set (DIDS)
- National Cancer Waiting Times Monitoring Data Set (CWT)
The pseudonymised data is required to for the following purposes:
§ Population health management:
• Understanding the interdependency of care services
• Targeting care more effectively
• Using value as the redesign principle
§ Data Quality and Validation – allowing data quality checks on the submitted data
§ Thoroughly investigating the needs of the population, to ensure the right services are available for individuals when and where they need them
§ Understanding cohorts of residents who are at risk of becoming users of some of the more expensive services, to better understand and manage those needs
§ Monitoring population health and care interactions to understand where people may slip through the net, or where the provision of care may be being duplicated
§ Modelling activity across all data sets to understand how services interact with each other, and to understand how changes in one service may affect flows through another
§ Service redesign
§ Health Needs Assessment – identification of underlying disease prevalence within the local population
§ Patient stratification and predictive modelling - to identify specific patients at risk of requiring hospital admission and other avoidable factors such as risk of falls, computed using algorithms executed against linked de-identified data, and identification of future service delivery models

The pseudonymised data is required to ensure that analysis of health care provision can be completed to support the needs of the health profile of the population within the CCG area based on the full analysis of multiple pseudonymised datasets.
Processing for commissioning will be conducted by MedeAnalytics


National identifiers will be removed by NHS Digital (DSCRO) using MedeAnalytics’ Pseudonymisation at Source process, prior to data leaving NHS Digital. By using the MedeAnalytics process, the resulting de-identified data can be linked within the MedeAnalytics system with data from other providers (as specified in this application) using the same process, without the need for identifiable data to flow to MedeAnalytics.

Further, as national identifiers are removed by NHS Digital before transmission, thus together with other approaches rendering the data Anonymous in line with the ICO’s anonymisation code of practice, the resulting, non-identifiable data representing 100% of the commissioner’s records is suitable for General Commissioning and Contract Validation purposes, both of which have been previously approved. As data Is anonymous in context, there is no need to remove records for type 2 objectors, as the records are no longer identifiable when they leave the protected NHS Digital environment.

Where analysis of pseudonymised patient records show that the associated patients could benefit from clinical interventions, GP Practice users who have legitimate relationships with the patients will be able to re-identify the patient records so that they can provide the interventions (direct care).

Yielded Benefits:

Benefits to date are in line with what we expected to achieve at the point in time as described in the previous application. The continued access to this data will enable the CCG to further understand and improve service performance and delivery, including patient pathway design, re-design and patient experience.

Expected Benefits:

Invoice Validation

1. Financial validation of activity
2. CCG Budget control
3. Commissioning and performance management
4. Meeting commissioning objectives without compromising patient confidentiality
5. The avoidance of misappropriation of public funds to ensure the on going delivery of patient care

Commissioning

1. Supporting Quality Innovation Productivity and Prevention (QIPP) to review demand management, integrated care and pathways.
a. Analysis to support full business cases.
b. Develop business models.
c. Monitor In year projects.
2. Supporting Joint Strategic Needs Assessment (JSNA) for specific disease types.
3. Health economic modelling using:
a. Analysis on provider performance against 18 weeks wait targets.
b. Learning from and predicting likely patient pathways for certain conditions, in order to influence early interventions and other treatments for patients.
c. Analysis of outcome measures for differential treatments, accounting for the full patient pathway.
d. Analysis to understand emergency care and linking A&E and Emergency Urgent Care Flows (EUCC).
4. Commissioning cycle support for grouping and re-costing previous activity.
5. Enables monitoring of:
a. CCG outcome indicators.
b. Non-financial validation of activity.
c. Successful delivery of integrated care within the CCG.
d. Checking frequent or multiple attendances to improve early intervention and avoid admissions.
e. Case management.
f. Care service planning.
g. Commissioning and performance management.
h. List size verification by GP practices.
i. Understanding the care of patients in nursing homes.
6. Feedback to NHS service providers on data quality at an aggregate and individual record level – only on data initially provided by the service providers.
7. Improved planning by better understanding patient flows through the healthcare system, thus allowing commissioners to design appropriate pathways to improve patient flow and allowing commissioners to identify priorities and identify plans to address these.
8. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services and early intervention of appropriate care.
9. Improved access to services by identifying which services may be in demand but have poor access, and from this identify areas where improvement is required.
10. Potentially reduced premature mortality by more targeted intervention in primary care, which supports the commissioner to meets its requirement to reduce premature mortality in line with the CCG Outcome Framework.
11. Better understanding of the health of and the variations in health outcomes within the population to help understand local population characteristics.
12. Better understanding of contract requirements, contract execution, and required services for management of existing contracts, and to assist with identification and planning of future contracts
13. Insights into patient outcomes, and identification of the possible efficacy of outcomes-based contracting opportunities.
All of the above lead to improved patient experience through more effective commissioning of services. Users of the same MedeAnalytics service have feedback that:
Showing the number of benchmarked A&E admissions (and A&E attendances in the next analysis) from specific local geographical locations in a heat map, will enable the CCG and providers to direct our finite health and social care (public health) resources more efficiently and effectively.
Users can better understand variation in their system, and make comparisons between populations and organisations in a fair and meaningful way with a greater understanding of what normal is. This will support routine opportunity analyses that they carry out in order to best target resources and best understand which activities have had a genuine benefit, and helped reduce costs to the system.
In addition, the platform provides access to comprehensive supporting information that commissioning organisations such as Clinical Commissioning Groups use to ensure that the services they commission:
• deliver the best outcomes for their patients
• cater for and meet the needs of the population they are responsible for;
• monitor condition prevalence within the population
• identify health inequalities and work with local organisations and agencies to remove them

Outputs:

Invoice Validation

1. Addressing poor data quality issues
2. Production of reports for business intelligence
3. Budget reporting
4. Validation of invoices for non-contracted events

Commissioning

General reporting
1. Commissioner reporting:
a. Summary by provider view - plan & actuals year to date (YTD).
b. Summary by Patient Outcome Data (POD) view - plan & actuals YTD.
c. Summary by provider view - activity & finance variance by POD.
d. Planned care by provider view - activity & finance plan & actuals YTD.
e. Planned care by POD view - activity plan & actuals YTD.
f. Provider reporting.
g. Statutory returns.
h. Statutory returns - monthly activity return.
i. Statutory returns - quarterly activity return.
j. Delayed discharges.
k. Quality & performance referral to treatment reporting.
2. Readmissions analysis.
3. Production of aggregate reports for CCG Business Intelligence.
4. Production of project / programme level dashboards.
5. Monitoring of acute / community / mental health quality matrix.
6. Clinical coding reviews / audits.
7. Budget reporting down to individual GP Practice level.
8. GP Practice level dashboard reports include high flyers.
Analytics Insights
Reports, charts and dashboards providing insights into:
1. Comparators of CCG performance with similar CCGs as set out by a specific range of care quality and performance measures detailed activity and cost reports
2. Data Quality and Validation measures allowing data quality checks on the submitted data
3. Contract Management and Modelling
4. Patient Stratification, such as:
o Patients at highest risk of admission
o Most expensive patients (top 15%)
o Frail and elderly
o Patients that are currently in hospital
o Patients with most referrals to secondary care
o Patients with most emergency activity
o Patients with most expensive prescriptions
o Patients recently moving from one care setting to another
i. Discharged from hospital
ii. Discharged from community
5. Understanding impacts and interdependency of care services

Processing:

Data must only be used as stipulated within this Data Sharing Agreement.

Data Processors must only act upon specific instructions from the Data Controller.

Data can only be stored at the addresses listed under storage addresses.

Patient level data will not be shared outside of the CCG unless it is for the purpose of Direct Care, where it may be shared only with those health professionals who have a legitimate relationship with the patient and a legitimate reason to access the data.

All access to data is managed under Roles-Based Access Controls

No patient level data will be linked other than as specifically detailed within this agreement. Data will only be shared with those parties listed and will only be used for the purposes laid out in the application/agreement. The data to be released from NHS Digital will not be national data, but only that data relating to the specific locality and that data required by the applicant.

NHS Digital reminds all organisations party to this agreement of the need to comply with the Data Sharing Framework Contract requirements, including those regarding the use (and purposes of that use) by “Personnel” (as defined within the Data Sharing Framework Contract ie: employees, agents and contractors of the Data Recipient who may have access to that data)

Segregation
Where the Data Processor and/or the Data Controller hold both identifiable and pseudonymised data, the data will be held separately so data cannot be linked.

All access to data is auditable by NHS Digital.

Data for the purpose of Invoice Validation is kept within the CEfF, and only used by staff properly trained and authorised for the activity. Only CEfF staff are able to access data in the CEfF and only CEfF staff operate the invoice validation process within the CEfF. Data flows directly in to the CEfF from the DSCRO and from the providers – it does not flow through any other processors.

Data Minimisation
Data Minimisation in relation to the data sets listed within section 3 are listed below. This also includes the purpose on which they would be applied -

For the purpose of Commissioning:
• Patients who are normally registered and/or resident within the commissioner (including historical activity where the patient was previously registered or resident in another commissioner).
and/or
• Patients treated by a provider where the commissioner is the host/co-ordinating commissioner and/or has the primary responsibility for the provider services in the local health economy – this is only for commissioning and relates to both national and local flows.
and/or
• Activity identified by the provider and recorded as such within national systems (such as SUS+) as for the attention of the commissioner - this is only for commissioning and relates to both national and local flows.

For the purpose of Invoice Validation:
• CCG of residence and/or registration.

The above relates to data requested only (Table 3B). Data currently held (Table 3A) will have the following Data Minimisation:
• CCG of residence and/or registration.

Invoice Validation

1. Identifiable SUS+ Data is obtained from the SUS+ Repository by the Data Services for Commissioners Regional Office (DSCRO).
2. The DSCRO pushes a one-way data flow of SUS+ data into the Controlled Environment for Finance (CEfF) located in the CCG.
3. The CEfF conduct the following processing activities for invoice validation purposes:
a. Validating that the Clinical Commissioning Group is responsible for payment for the care of the individual by using SUS+ and/or backing flow data.
b. Once the backing information is received, this will be checked against national NHS and local commissioning policies as well as being checked against system access and reports provided by NHS Digital to confirm the payments are:
i. In line with Payment by Results tariffs
ii. In relation to a patient registered with the CCG GP or resident within the CCG area.
iii. The health care provided should be paid by the CCG in line with CCG guidance. 
4. The CCG are notified by the CEfF that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved


Commissioning

The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1. SUS+
2. Local Provider Flows (received directly from providers)
a. Acute
b. Ambulance
c. Community
d. Demand for Service
e. Diagnostic Service
f. Emergency Care
g. Experience, Quality and Outcomes
h. Mental Health
i. Other Not Elsewhere Classified
j. Population Data
k. Primary Care Services
l. Public Health Screening
3. Mental Health Minimum Data Set (MHMDS)
4. Mental Health Learning Disability Data Set (MHLDDS)
5. Mental Health Services Data Set (MHSDS)
6. Maternity Services Data Set (MSDS)
7. Improving Access to Psychological Therapy (IAPT)
8. Child and Young People Health Service (CYPHS)
9. Community Services Data Set (CSDS)
10. Diagnostic Imaging Data Set (DIDS)
11. National Cancer Waiting Times Monitoring Data Set (CWT)

Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:

Data Processor 1 – MedeAnalytics

1. Pseudonymised SUS+, Local Provider data, Mental Health data (MHSDS, MHMDS, MHLDDS), Maternity data (MSDS), Improving Access to Psychological Therapies data (IAPT), Child and Young People’s Health data (CYPHS), Community Services Data Set (CSDS). Diagnostic Imaging data (DIDS) and National Cancer Waiting Times Monitoring Data Set (CWT) only is securely transferred from the DSCRO to MedeAnalytics.
2. MedeAnalytics add derived fields, link data and provide analysis to:
a. See patient journeys for pathways or service design, re-design and de-commissioning.
b. Check recorded activity against contracts or invoices and facilitate discussions with providers.
c. Undertake population health management
d. Undertake data quality and validation checks
e. Thoroughly investigate the needs of the population
f. Understand cohorts of residents who are at risk
g. Conduct Health Needs Assessments
2. Records contain no national identifiers, but do contain the following local identifiers: [Local Patient Identifier], [Hospital Provider Spell No], [Unique CDS Identifier], [Attendance Identifier], and [A&E Attendance Number]
3. On arrival at Medeanalytics International Limited, one of the Medeanalytics International Limited operational staff then transfers the data from the secure landing zone to the ETL process. The Extract Transform Load (ETL) process then loads the data into the Medeanalytics International Limited system, where it is linked.
4. Allowed linkage is between the data sets contained within point 1 and the following data that is pseudonymised at source using the Medeanalytics pseudonymisation tool:
o Social Care data
o GP Practice data
o Community data
o Mental Health data
5. Medeanalytics provides analysis to:
a. See patient journeys for pathways or service design, re-design and de-commissioning.
b. Check recorded activity against contracts or invoices and facilitate discussions with providers.
c. Undertake population health management.
d. Undertake data quality and validation checks.
e. Thoroughly investigate the needs of the population.
f. Understand cohorts of residents who are at risk.
g. Conduct health needs assessments.
6. Access is fully controlled by Role Based Access Control (RBAC), signed off by Caldicott Guardians/SIROs.
7. CCGs use the workflow features provided by the Medeanalytics International Limited Contract Validation Module to check recorded activity against contracts, and facilitate contract discussions with providers
8. CCG users use online features of the Medeanalytics International Limited system to produce reports, charts and dashboards to analyse the data for the purposes listed.
9. Aggregation of required data for CCG management use will be completed by Medeanalytics or the CCG as instructed by the CCG.
10. Patient level data will not be shared outside of the CCG and will only be shared within the CCG on a need to know basis, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared as set out within the NHS Digital guidance applicable to each data set.

Segregation
Data is held within the MedeAnalytics system, and is segregated according to contract.
Only MedeAnalytics operational staff (currently 4 individuals operating under full time MedeAnalytics employment contracts) have access to data prior to loading into the main system.
All staff at MedeAnalytics undertake compulsory IG Toolkit training every year.
All MedeAnalytics staff understand their responsibilities with regard to receiving, storage, processing and handling of data, and contractual sanctions that can result in disciplinary actions including dismissal for contraventions are included in employee contracts.
Specific processes are in place to setup new system users, all of which require Caldicott Guardian or SIRO sign-off in order to obtain user identities and passwords. Identities and passwords are restricted to specific subsets of data according to their roles, so that a CCG user can only see data for their own CCG, and a GP user can only see data for their own GP Practice.
All access to data is managed under Roles-Based Access Controls (RBAC).
Access to data is provided through the MedeAnalytics front end interfaces, for on-line access; while it is reasonable and allowable for users to export the results displayed in reports, charts and dashboards, so that the results can be used in board presentations, reports and other management documents, bulk export of underlying linked data sets is not possible.
All accesses are audited
CCG staff are only able to access data pertinent to their own CCG.
GP Practice staff are only able to access data for patients registered to their own practice.
Re-identification (managed under RBAC) requires an additional step to access re-identification keys held by an independent third party key management service (operated by BMS) that has no access to the data. Disabling a user’s account in the key management system immediately removes the ability of that user to access re-identification keys.
Each Re-identification requires a different key, so inappropriate retention of keys (which is neither allowed, nor easy to accomplish by design) will not result in compromise of data.
Only GP Practice users are able to re-identify patients and only when they have a legitimate reason and a legal right to re-identify have access to encrypted data, and can only access data to which they have rights under RBAC (which is CCG/SIRO approved– within the CCG).
All data providers for a particular region (according to contract) are issued with encryption keys that ensure data for their region can only be linked to data from other providers for the same region. This means that data for two different regional customers cannot be accidentally mixed.

Commissioning – Pseudonymised – Local Flows
Management of services for non-contracted activities
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1. Local Provider Flows (received directly from providers)
a. Acute
b. Ambulance
c. Community
d. Diagnostic Service
e. Primary Care Services
Data quality management and pseudonymisation is completed within the DSCRO is then disseminated as follows:
2. DSCRO then remove national identifiers to Pseudonymise the data
3. CCG staff then download the processed, Pseudonymised data from the DSCRO. The CCG analyse the data to see patient journeys for pathways or service design, re-design and commissioning.
4. Aggregation of required data for CCG management use will be completed by the CCG.
5. Patient level data will not be shared outside of the CCG and will only be shared within the CCG on a need to know basis, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared as set out within NHS Digital guidance applicable to each data set.