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Joined: 15 Jan 2007
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 Posted: Wed, 22 Aug 2007 15:19:34 +0000 Post subject: BMA: Letter to Ben Bradshaw from BMA re NPfIT/SCR |
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from BMA website (logon required):
| Quote: | Letter from Hamish Meldrum to Ben Bradshaw, Minister of State for Health Services, on the National Programme for IT
August 2007
The National Programme for IT (NPfIT) is an important but contentious aspect of health policy. I would like to take this opportunity to express the BMA’s hopes, to raise our concerns and to suggest recommendations as to what the programme should deliver to support patient care. I hope this will help inform debate at this crucial time for re-defining the future of the programme.
The BMA wants to see the programme succeed. We recognise that there have been some successes. We believe that with a change in leadership it is an appropriate time to review progress and set out a clear strategy for the future of the programme.
At the BMA’s recent Annual Representatives Meeting, doctors from both primary and secondary care expressed their frustration about the programme. Doctors called for a public inquiry to review the problems encountered by Connecting for Health (NHS CfH), the cost to the tax payer and whether this has been a cost effective use of public funds.
The BMA believes there are some essential steps that must be taken to sustain successful delivery.
(i) Renewed engagement with system users
1. Provide greater clarity about the NPfIT Local Ownership Programme, how it will improve engagement and what it will mean for clinicians and patients.
2. Introduce an open, two-way reporting mechanism, which allows users to highlight problems with systems and suppliers to feed back what steps are being taken to address these issues and within what timeframe.
3. Renew engagement and confidence by delivering some quick wins, focusing on areas which are proving successful and holding a series of secondary care roadshows to listen to feedback and address misconceptions
4. Work with the BMA to address the continuing issues with Choose and Book.
(ii) Generate confidence in the Summary Care Recor
5. No further roll out of the Summary Care Record (SCR), beyond the six early adopter PCTs, until the independent review has been completed and ways forward have been agreed by the Summary Care Record Advisory Group.
6. Work with the BMA to agree a code of practice/service level agreement for uploading information onto the SCR.
7. Seek a definitive legal opinion on the issues raised during the Health Select Committee hearings concerning the legality of the SCR and the Data Protection Act in relation to EU directives that can be agreed with the profession and patients alike.
8. Work with the BMA, Medical Defence Organisations and patient organisations to agree the final Public Information Campaign material so that together we can persuade PCTs to use an agreed standard package of information.
(iii) Tackle implementation issues in Secondary Care
9. Negotiate a choice of systems for secondary care within an agreed framework.
10. Establish a national implementation checklist, which must be completed before the implementation of any PAS.
11. Incorporate information governance and electronic records into the medical student curriculum and allow medical students access to the SCR.
(iv) Provide clarity about the Secondary Uses Service
12. Provide clarity about the Secondary Uses Service (SUS) including creating an area on the new NHS Choices website where patients can view details of how data is used for Secondary Uses.
I have provided further detail in the enclosed paper. I hope that these recommendations provide a helpful insight into our concerns, and that they inform your discussion. I would welcome your view on how we might work together on these recommendations.
I look forward to hearing from you.
Dr Hamish Meldrum
Chairman of Council |
additional paper sent I believe, expanding on SCR:
| Quote: | Generate confidence in the Summary Care Record
5. No further roll out of the Summary Care Record (SCR), beyond the six early adopter PCTs, until the independent review has been completed and ways forward have been agreed by the Summary Care Record Advisory Group.
One of the prime concerns about NPfIT is in relation to security and confidentiality controls. Doctors are responsible for ensuring the confidentiality of the information provided to them by patients. Despite NHS CfH informing doctors that the security arrangements meet the highest standards, doctors remain cautious until they, or their colleagues, have experienced this themselves and can address firsthand any concerns patients may have rather than passing on assurances provided by the government.
The early adopter phase is the first step in providing this opportunity and we welcome the commitment to conduct an independent review. The SCR must not be rolled out beyond the six early adopter PCTs until the results of the independent review have been made public and ways forward have been agreed by the Summary Care Record Advisory Group. A delay of a few months will not make much difference to the roll out of the programme but could make a real difference in terms of NHS CfH being seen to listen. This in itself will generate greater confidence. The BMA will advise its members, who are not involved in the early adopter phase, against uploading information onto the SCR until the review has been published so that lessons can be learnt before further roll out.
Role Based Access Controls and alerting processes have not yet been fully incorporated into the Early Adopter phase and we would welcome clarity about how these processes will be rolled out and piloted.
6. Work with the BMA to agree a code of practice/service level agreement for uploading information onto the SCR.
Changing the way information is managed presents a new challenge for the NHS. Staff are unsure of what is expected of them. Questions remain unanswered about multi-contributory records which does not generate confidence. For example, what data will be contained in a SCR? How often should data be uploaded? The BMA recommends that a code of practice or Service Level Agreement is agreed between NHS CfH and the BMA, with input from the Medical Defence Organisations. This should set out what is expected from doctors in relation to uploading and sharing information. This will help prevent misunderstandings which could put patient care at threat and help us work through the information governance questions, which remain unanswered.
7. Seek a definitive legal opinion on the issues raised during the Health Select Committee hearings, concerning the legality of the SCR and the Data Protection Act in relation to the EU Directives that can be agreed with the profession and patients alike.
At the recent Local Medical Committee’s Conference, GPs voted in support of seeking complete clarity in relation to the legality of the SCR. There is concern that by uploading patient data to the NHS Care Records Service doctors could be in breach of the Data Protection Act and GMC guidance on patient confidentiality. There is also concern about the recommendations of the European Article 29 Data Protection Working Party, which if adopted, some legal experts believe would conflict with the Programme. Seeking a definitive legal opinion will reassure clinicians and staff that they are acting lawfully when uploading patient data and consequently help generate confidence in the NHS Care Records Service.
8. Work with the BMA, Medical Defence Organisations and patient organisations to agree the Public Information Campaign material so that together we can persuade PCTs to use an agreed standard package of information.
Consent in relation to uploading information onto the central spine has been a difficult area. The crux of the issue is the extent to which patients are properly informed, understand how their information will be shared and what choices they have if they wish to restrict sharing. In relation to the early adopter sites the MDU has advised that GPs have a responsibility to consider the effectiveness of the public information campaign and whether they can rely on implied consent. The BMA has been forwarded an example of locally tailored material, from the early adopter sites, which was felt to be inappropriate. Following the evaluation of the effectiveness of the public information campaign in the early adopter practices, the BMA recommends that NHS CfH engages with the Medical Defence Organisations and the BMA to agree a final version of the material. The BMA, the MDU and hopefully other defence organisations will advise their members to insist that PCTs use the agreed version. This will ensure that the material meets an agreed standard and will help prevent patients receiving substandard information due to local tailoring. It will also provide doctors with greater confidence that their patients have been properly informed of the changes. |
| Quote: | Provide clarity about the Secondary Uses Service
12. Provide clarity about the Secondary Uses Service including creating an area on the new NHS Choices website where patients can view details of how data is used for Secondary Uses.
There needs to be complete clarity for both clinicians and patients about how data will be used for secondary uses. The BMA welcomed the establishment of the Care Records Development Board Secondary Uses Working Group but is concerned about the delays in publishing the report of this group. There remain many unanswered questions and concerns about the Secondary Uses Service. We hope that this report will provide some answers and generate some open debate.
Section 60 of the Health and Social Care Act 2001 was introduced by Lord Hunt as a temporary measure until consent or anonymisation procedures were developed in the NHS. When debated in parliament, it was stated that section 60 would only be used in exceptional circumstances. Recently we have been extremely concerned about large amounts of identifiable data being made available under Section 60 following PIAG approval. This data has been subsequently made available to a private company without being fully anonymised. We also understand that PCTs have access to large amounts of patient identifiable data. Access to confidential data via the Secondary Uses Service will undermine even further confidence in the entire system.
We recommend that as part of the new NHS Choices website there should be a detailed page, which allows patients to see the way data is used for Secondary Uses, why and the benefits it brings. |
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