Data integrity - Submitting data in line with the NHS Data Dictionary

Data senders are directly responsible for the integrity of the CDS data they submit. This means that data senders must not flow legally restricted or identifiable information using data items that are not designed for this purpose. Data senders must adhere to the specific guidance for each CDS data item in the NHS Data Dictionary.  Failure to follow the guidance for each data item may constitute a breach of the Data Protection Act. Further security and confidentiality information is available on the following webpages of the Submission Protocol and Security Issues and Patient Confidentiality webpages of the NHS Data Dictionary.

Information on populating APC CDS Type can be found via the link below.  Other CDS Types can be found in the left-hand menu.

CDS V6-2 Type 130 - Admitted Patient Care - Finished General Episode Commissioning Data Set. 

The Prime Recipient CDS data item should be populated in accordance with the Addressing Grid. The code of a NHS England Region (formerly Local Area Team) should not be used in this data item, even where the NHS England Region is responsible for commissioning the activity. This is because it is not possible to derive postcode which is required for Prime Recipient.

NHS England region codes should be submitted in the copy recipient or Organisation Code (Code of Commissioner) CDS data items.

Users are advised to contact NHS England for further guidance on policy.

A date prior to 01/01/1880 or later than the CDS activity date constitutes an invalid date of birth.

If an invalid date of birth is submitted the associated record will delay PbR processing for the submitting organisation.

Provider organisations are advised to carefully review and validate the population of the DoB data item prior to submission.

Submitting data to SUS is a mandatory requirement outlined in the NHS Standard Contract 2015/16.

The provider must submit commissioning data sets to SUS in accordance with SUS Guidance, where applicable. Where SUS is applicable, if:

1. there is a failure of SUS; or
2. there is an interruption in the availability of SUS to the Provider or to any commissioner, the provider must comply with guidance issued by NHS England and/or NHS Digital in relation to the submission of the national datasets collected in accordance with this SC28 pending resumption of service and must submit those national datasets to SUS as soon as reasonably practicable after resumption of service.

To translate this requirement into local practice:

1.    Providers and commissioners should use SUS as the definitive source of data for patient activity and where a national tariff is applicable, for the price calculation as well. It is recognised that there are some areas where further information is needed in addition to SUS data to implement tariff policy. The areas are:
⦁    some best practice tariffs
⦁    marginal rate for emergency admissions
⦁    Non-payment for emergency readmission

2. To confirm all activity has been captured and locally agreed tariffs have been applied, providers and commissioners will need to reconcile local data and billing systems to SUS, to a jointly acceptable level of tolerance. 

Providers and commissioners should document in their service agreements the method by which they will reconcile local billing systems with SUS data.

Commissioning data sets (CDS) for patient activity not covered by PbR should still be submitted to SUS. Providers should flag activity that is subject to locally agreed tariffs in order to support reconciliation. This can be achieved by using the service agreement data items in the relevant CDS.  Further guidance is available in the Locally Priced Activity chapter of the SUS PbR reference manual.

3.    As a means to improve the quality of data submitted to SUS, commissioners should apply measures and conditions to the timeliness and accuracy of provider submissions as reflected in the service agreement.

4.    To effectively reconcile local systems with SUS, providers and commissioners should apply NHS Digital guidance in conjunction with local NHS communities.

• use consistent snapshots of data from local systems and SUS.  For SUS snapshots, it is strongly recommended that extracts should be taken using the PbR
• reconciliation and post‐ reconciliation views.
• use SUS PbR as the basis for reconciliation. The Standard Extract Mart (SEM) view is much more difficult to use for this purpose. SUS PbR processing is applied in a consistent manner according to published DH policy and also effectively handles all activity that is subject to policy exclusion.
• ensure all episodes in a spell are updated (coded) and then extracted.
• ensure that local payment systems apply rules that are consistent with those applied by SUS.

Further guidance is available in the Reconciling SUS PbR with local systems chapter of the SUS PbR reference manual.

Where a patient requests their identifiable PCD data items not to flow, (known as ‘patient objections’ or ‘removal of consent’) providers are required to remove all person confidential data from the CDS file for the data items identified in the legally restricted records section of Submitting CDS Data to SUS, thus making these patient records anonymous.  No substitute or pseudonym values should be submitted in their place.

The objecting patient’s identity should be appropriately verified in line with an organisation’s information governance guidance and the Data Protection Act 1998. It may be appropriate for this aspect to be managed through an organisation’s information governance department.