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Current Chapter

Current chapter – Recommendations for the future


1. The programme should now seek to acquire senior sponsorship from both NHS England and the Department of Health and Social Care (DHSC). This will enable senior sponsorship and engagement concomitant with the vision of the programme and the scale of the strategic opportunities it can help unlock across the wider healthcare sector. 

2. DHSC should issue a Direction to NHS Digital to require the collection of all private Admitted Patient Care and Outpatient data. This will make use of the new power to collect data from private healthcare providers granted under the Health and Social Care Act 2022. 

3. The Direction in respect of the collection of private Admitted Patient Care and Outpatient data should take effect from 1 April 2024. This will allow a transition period during which private providers can develop skills and capacity in respect of Secondary Uses Service (SUS) submission.

4. The sharing of private Admitted Patient Care data between NHS Digital and the Private Healthcare Information Network (PHIN) should continue on an interim basis until at least 31 March 2024. There is obvious value in the NHS collecting and processing private healthcare data to support linkage to NHS-funded activity data and for consultant whole-practice analysis. This would support the range of stakeholder use cases demonstrated by ADAPt pilot 1 and enable work to continue ahead of 1 April 2024 (at which time the suggested Direction would come into force). Also, although the pilots have established that there are no insurmountable technical barriers to flowing private APC data into NHS systems using the existing SUS infrastructure, smaller providers may need longer to develop technical capability and plan for potential cost increases which might delay their uptake. PHIN could therefore continue to act as a conduit for their data beyond 31 March 2024.

5. The legal basis for this interim processing should be defined in collaboration with independent healthcare providers. Support and agreement from the independent sector will be needed (especially in the absence of a Direction). This will have a dependency on the purposes for which the data will be used and the recognition of the data’s inherent commercial sensitivities.

6. All private healthcare providers should begin to collect NHS number, date of birth, postcode and gender1 as soon as practicable. 

7. NHS organisations should continue to make secondary submissions of their private activity data to PHIN pending a data sharing agreement between PHIN and NHS Digital. This is because pilot 2 failed to demonstrate the use by PHIN of SUS data as an alternative to directly submitted APC data from NHS PPUs due to an inability to establish a timely DARS agreement between PHIN and NHS Digital. This pilot was also intended to demonstrate the opportunity to reduce the burden of data collection on NHS organisations. Until this aspect of data collection can be demonstrated, NHS organisations will need to continue to make secondary submissions of their private activity data directly to PHIN.

8. NHS Digital and PHIN should continue to work closely together to ensure consistency of approach with regard to issues such as data specifications, data linkage and case mix adjustment.

1Currently 'person stated gender' is used in datasets more often than 'person phenotypic sex'. 


Last edited: 30 November 2022 9:58 am