National Update: The information revolution and the 2012 Caldicott ReviewSimon Richardson – Information Rights Manager

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The Information Revolution

Source: www.freeimages.co.uk

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Background

• Structural change across sector – particularly NHS

• Significant change within Info Gov leadership structure

• Financial restraints

• Move away from National IT programme

• Liberating the NHS: ‘No decision about me, without me’

• Regulatory change

CQC perspective on regulation of information governance in health and social care, and improving practice.

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As things are/were

• National Information Governance Board (NIGB)

• Guidance and coordination

• Advice to Secretary of State

• Section 251

• DH / Connecting for Health

• IG Toolkit

• Policy and controls

• Information Standards Board for Health and Social Care

• Information standards

• Information Commissioner’s Office (ICO)

• DPA guidance and enforcement

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As things are/were

• Individual health and social care providers

• Established relationships

• Agreements and processes

• Contractual arrangements

• Professional regulators

• Professional standards

• Fitness to Practice

• CQC

• Essential standards of quality and safety

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The emerging scene

• NHS / private provision

• Department of Health

• Strategy – ‘The Power of Information’

• Policy

• NHS Commissioning Board

• Leadership role

• Information Standards

• Delivery

• Health and Social Care Information Centre

• Information systems - collect and disseminate information

• Health Research Authority

• Section 251?

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The power of information

Source: The Power of Information – Dept of Health 2012

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The power of information

• Move to electronic records and sharing

• Challenge for some smaller providers

• Adult social care – >25% paper registration

• Shift of strategic approach from central, imposed system to local systems

• Reliance on information standards to ensure effective integration

• Reliance on IT Sector to produce ‘innovative solutions’

• Information Centre role

• Uses of technology create efficiency – anticipated that this will free up time for those requiring face to face support.

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The power of information

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CQC’s new functions

Health and Social Care Act 2012 – section 280

• To monitor the practice of registered persons (providers and managers) in relation to processing personal information, and information derived from personal information.

• To keep the NHS CB and Monitor informed about the practice.

In exercising these functions, CQC must seek to improve that practice.

• Secretary of State to consult with CQC on any new regulations

• CQC required to establish a ‘National Information Governance Committee’ to advise and assist CQC in the exercise of these functions, and to maintain this committee until 31 March 2015.

CQC functions and the role of the NIGC are NOT the same as the NIGB 

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CQC as an IG regulator?

• IG Toolkit as a source of intelligence

• Focus on quality and safety of care

• Look at experiences of care - ‘Outcomes’

• Regulate / enforce against H&SCA 2008 (Regulated Activities) Regulations 2010

•Privacy and dignity (within Reg 17 – Outcome 1)

•Business continuity (within Reg 9 – Outcome 4)

•Information sharing (within Reg 24 – Outcome 6)

•Training (within Reg 23 – Outcome 14)

•Assess and monitor quality of service (within Reg 10 – Outcome 16)

•Records – quality, security, retention, disposal (within Reg 20 – Outcome 21)

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CQC findings to date

• Cooperation with other providers

• 3494 completed inspections (as of July 2012)

• 99% compliance rate

• Records

• 5156 completed inspections (as of July 2012)

• 84% compliance rate

• By comparison, 22134 inspections against outcome for ‘care and welfare of people who use services’ (90%) and 18905 inspections against outcome for ‘safeguarding against abuse’ (93% compliance)

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‘The right information, in the right place, at the right time’ (2009)

• “while the basic systems may be in place, some of the more detailed elements that help to ensure safe, high quality care, are missing”.

• “the systems for collecting and analysing data from these different sectors [NHS, IHC, ASC] have developed separately, and this has hampered comparisons of performance between them”.

• “support for the principles of sharing information between health and social care providers, but there were technical and cultural barriers to this”.

• “Generally, organisations do not systematically use information that may be unrelated to a patient’s clinical needs to tailor their care to their individual needs or those of their family”.

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‘Supporting life after stroke’ (2011)

• “If people’s experiences of care are to be seamless, then services need to work in a coordinated way”.

• “While policies are generally in place to involve adult social services in planning transfer home, there are many opportunities to improve integration of health and social services. For example, only 26% of areas produce information jointly on care and support after stroke and only 34% have a framework for joint reviews of people’s health and social needs across most or all of the PCT area. Only 40% of adult social services departments had systems in place to monitor what happens to people who are signposted to other sources of help”

• “Stroke pathways (policies setting out how care should be delivered) are in place, but do not always cover all relevant services”.

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CQC’s new function

Decisions for CQC Board to make over next few months:

• ‘Monitor and report’ – fit with regulation

• Balance individual inspection of IG issues / across-sector review

• Key priorities and use of resources

• NIGC – membership and ToR

Likely developments for CQC

• Inspectors more sensitive to IG issues

• Growing understanding of how IG issues can be indicative of broader organisational issues

• Improved understanding of how IG issues impact on the quality and safety of care

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Challenges for CQC

• Sources of intelligence

• Identifying key IG issues

• Understanding perceptions and expectations of people who use services

• Training and skills

• Reporting mechanisms and relationships

• CQC’s place in the IG system – relationships with strategic partners

• Sharing learning and promoting improvement

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CQC & the emerging IG system

• Caldicott review

• Protecting / sharing patient info

• Secondary uses

• Development of coordinated approach to IG

• Levers for improvement

• Links with key partners

• NHS CB

• Monitor

• ICO

• Opportunity for CQC to add value and new dimension to IG system

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Conclusions

• One player in the field

• NIGC – defined role

• Not becoming a specialist IG regulator, but increased focus on IG

• Growing understanding of IG adding value to broader role

• Opportunity for CQC to add value to existing systems and controls

• Information revolution taking place against background of change

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Questions?

Simon Richardson

Information Rights Manager

simon.richardson@cqc.org.uk

www.cqc.org.uk