Findings

The private APC data was analysed to assess:  

•  whether there are service delivery and patient care benefits in combining NHS and private healthcare data
• whether such collection could support a reduction in the reporting burden on NHS and private providers
• the feasibility of such information to meet a variety of other use cases, for example, derivation of performance metrics, the requirements of healthcare regulators and supporting authorised research

The pilots have assisted in establishing that key stakeholder scenarios could be met if private healthcare data was routinely collected and processed by NHS Digital and made available to customers via either the Data Access Request Service (DARS) or a Trusted Research Environment (TRE). 

The piloting has also helped to inform views on the future strategic direction of private healthcare information flows.

Below is a summary of the findings in respect of each pilot.

A number of customer use cases have been identified which could be met were NHS Digital to hold private healthcare data (the Care Quality Commission (CQC); researchers at a research organisation; the National Consultant Information Programme (NCIP), the Getting It Right First Time (GIRFT) Programme and the national cataract contract development team (all NHS England); also the Surgical Devices programme team in NHS Digital (Cumberlege)). See annex 1 for a summary table.

Effective analysis required NHS numbers, however these are not always available in private healthcare data. Other identifiers are not always sufficient to support accurate matching (such as postcode, age, sex).

Some data quality issues relating to NHS Number were identified within private healthcare APC data which may impact NHS Digital’s ability to accurately meet some customer use cases.

The needs of customers can initially be met by utilising a data feed from PHIN.

The combination of NHS Digital’s legal powers (to require and request data further to a Direction), its governance processes (such as Information Governance expertise and the development of Data Protection Impact Assessments), organisational abilities (multi-disciplinary teams) and technical abilities (such as Secondary Uses Service (SUS) development expertise, Messaging Exchange for Health and Social Care (MESH), DARS) make NHS Digital the organisation best placed to host and disseminate private healthcare data.

However using NHS Digital does not solve the problem of handling cross-border data flows with the devolved administrations (NHS Digital’s remit is England-only whereas PHIN’s is UK-wide).

Overseas private patients may neither have nor require NHS numbers.

Pilot 2 has not yet concluded. There have been significant delays in DARS approval for this extract and the ADAPt programme continues to liaise with DARS and Advisory Group for Data (AGD) to facilitate this data flow. 

The ADAPt programme board has agreed to continue progressing the application so that data from NHSD and PHIN submissions can be compared; however with successful completion of pilot 1 and pilot 3 no significant variation is expected. The programme has agreed to move forward to ADAPt phase 3 prior to pilot 2 concluding and will publish a corrigendum to this report once pilot 2 has reported.

XML middleware suppliers can support private healthcare providers to submit activity data into NHS Digital without significant technical development or burden being required at a relatively low cost.

An increased number of private healthcare providers have now gained experience of submitting data to SUS (NB this includes those holding backfill contracts in respect of COVID-19 work in support of reducing waiting lists).

SUS overwrites data submitted by the same organisation in respect of a same time period; this raises a risk of one set of data being deleted if an organisation submits both NHS and private data for the same time period. This risk is mitigated by using a new/different Electronic Data Interchange address for the private healthcare data.

Some private healthcare providers do not have Organisational Data Service (ODS) codes. ODS codes identify individual organisations (including subsites) and are a prerequisite for submitting data to SUS and some other NHS Digital services). These can be requested from NHS Digital’s ODS service.

Collection of private healthcare APC data via NHS Digital's Secondary Uses Service (SUS) would meet PHIN's CMA Private Healthcare Investigation Order 2014 legal requirement - however some private providers may find this technically challenging to achieve in the short term.

The development of CDS 6.3 provided an opportunity for submission of some of the items collected by PHIN not previously supported by SUS, such as ASA score and BMI as SNOMED clinical observation codes.

Difference in validation in SUS compared to PHIN needs to be understood in depth and perhaps aligned further.

Need to understand for certain if there are any CDS items critical to PHIN processing that NHS Digital may no longer use. 

Guaranteeing that PHIN will continue to receive private healthcare APC data to meet their CMA Private Healthcare Investigation Order 2014 (as amended) if the data were to be collected by NHS Digital.

Any additional terms and conditions required in relation to applicants requesting data via DARS due to commercial sensitivity issues.

Application of the National Data Opt-Out - particularly where the NHS Number is not available.

Other private healthcare data sets collected by PHIN, including Patient Reported Outcome Measures (PROMS)and adverse events.

Collection and processing of private healthcare APC data relating to devolved administrations by NHS Digital.