OFFICIAL
NHS England Information Reader BoxDirectorate
Medical / Operations and Information / Patients and Information
Nursing / Policy / Commissioning Development
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Publications Gateway Reference:
Document Purpose / Consultations
Document name / SCCI 2210: Consistent Identification Data Items Business Justification and Funding Statement
Author / Data Services for Commissioners, NHS England
Publication Date / TBC
Target Audience / Standardisation Committee for Care Information (SCCI)
NHS Digital Classification and Coding Standards
Information Standards Delivery
NHS Digital SIRO and Information Assurance
NHS Digital DSCRO Business Leads
Data Services for Commissioners
NHS Digital DSCRO Seconded Staff
Head of IG, NHS England
Regional Commissioning Leads
Commissioning Support Units (CSUs)
Operational Intelligence for Commissioning (OIC)
Clinical Commissioning Groups
SUS
Any qualified NHS provider
Additional Circulation List
Description / NHS England is developing a new information standard which is designed to ensure that a consistent set of patient and event identifiers is flown in all national data sets mandated with an Information Standard, in order to support effective data quality assessment, anonymisation and linkage of patient-level data.
Cross Reference
Superseded Documents
Action Required
Timing/Deadlines (if applicable)
Contact Details for further information / Simon Snowden
Data Development Team, DSfC
NHS England
4E60, Quarry House
Quarry Hill, Leeds
LS2 7UE
Version / Date / Amendment History
0.1 / 10/08/2016 / First draft for review
0.2 / 17/08/16 / Draft incorporating review comments
0.3 / 31/08/16 / Draft incorporating minor changes for consistency
Approvals / Role / Organisation / Version / Date
Jon Shingleton (Author) / Senior Manager, DSfC / NHS England / 0.1 / 10/08/16
Alex Porter (Reviewer) / Senior Manager, DSfC / NHS England / 0.2 / 17/08/16
Simon Snowden (Project Lead) / Manager, DSfC / NHS England / 0.3 / 31/08/16
Brent Walker (Senior Reviewer) / Deputy Head, DSfC / NHS England
1 Contents
2 Background 5
2.1 Core Identification Data Items 5
2.2 Rationale 5
2.3 Related Programmes 7
3 Current SCCI Status 7
3.1 Related Documents 8
3.2 Target Implementation Date 8
4 Scope 8
5 Planned Outputs 9
6 Expected Benefits 10
6.1 Improved Commissioning Decisions for All Patient Groups 10
6.2 Improved Ability to Support Integrated Care and Patient-Centric Analysis 10
6.3 Improved Use and Validation of NHS Number and Other Identifiers 11
6.4 Improved Compliance with Legal Requirements for Anonymisation 12
6.5 Improved Compliance with Patient Objections 12
6.6 Improved Efficiency and Interoperability of Data Collection, Transmission and Analysis 12
6.7 Benefit Summary 12
7 Implementation of the CIDIs 13
7.1 Inclusion and Processing of CIDIS in National Data Flows Mandated by an ISN 13
7.2 How CIDIs Will Manifest in Different Types of Data 13
7.2.1 Episodic data 13
7.2.2 Non-episodic data 13
7.3 National Data Exempt from Submitting CIDIs 13
8 Strategic and Policy Drivers 15
8.1 Impact on NHS Business 15
8.2 Strategic and Policy Drivers 15
9 Commissioning and Funding 16
9.1 Commissioning Organisation 16
9.2 Resource Estimate 16
9.3 Affordability Statement 16
10 Governance and Assurance 17
11 Key Stakeholders 18
12 Quality Management 19
12.1 Customer Quality Expectations 19
12.2 Acceptance Criteria 19
13 Timescales 20
13.1 Stage Timescale 20
13.2 Estimated Overall Timescale 20
14 Risks, Assumptions, Dependencies and Constraints 21
14.1 Risks 21
14.2 Assumptions 21
14.3 Dependencies 21
14.4 Constraints 22
15 High Level Operational or Service Management Considerations 23
16 Impact on Existing Standards 23
17 Appendices 24
17.1 A: Glossary of Terms 24
17.2 B: In-Scope National Data Sets 25
17.3 C: Evaluation of CIDIs’ Presence in National Data Sets 28
17.4 D: Prevalence of Consistent Identification Data Items when NHS Number is Missing by National Data Sets, 2014-15 (%) 29
17.5 E: Consistent Identification Data Items to Improve Data Quality, Patient Identification and Linkage 30
17.6 F: Impact of the Use of Additional Identifiers When NHS Number is Not Verified 31
2 Background
The Consistent Identification Data Items (CIDIs) are a fundamental standard to ensure that all data sets in scope contain sufficient data to support consistent de-identification of patients and to provide data for analytical purposes where identities cannot be shared.
2.1 Core Identification Data Items
The CIDIs are a collection of consistently defined patient, event and activity identifiers that will support the:
· Creation of a high quality commissioning pseudonym
· Delivery of data to support the whole range of commissioning activities, including contract management, needs assessment and service development
· Application of derivations for age and geographical analysis
· Creation of derivations for sensitive data whose identifiable data has to be supressed
The NHS number is the natural identifier of choice - but in the cases where it is not available, additional data items are required to support validation and the derivation of extra required fields. This proposal supports the NHS number data standard and recommendations to flow data for tracing where the NHS number is available, so there is no change to the volumes of patient identifiers flowing as a result of this standard. However, these core identifiers are not currentlyimplemented consistently in NHS data standards, nor are they routinely used to aggregate and derive statistics for patients whose identifiable information is withheld information, and this is what this data standard aims to address.
Once mandated, they will be required for inclusion in future data sets submitted to the Standardisation Committee for Care Information (SCCI) that fall within the project’s scoping criteria (as identified in Appendix B – to be ratified via the CIDIs Public Consultation) prior to receipt of an Information Standards Notice (ISN). They will apply to requests for both new data sets as a mandatory requirement of the SCCI process and updates to existing information standards via their normal maintenance processes. As such, the CIDIs will evolve in nationally-mandated data sets over time, and will not be immediately required following publication of the standard.
A significant proportion of the CIDIs are already present in national data flows (Appendix C) and the intention of this proposal is to ensure, over time, that all national flows contain them in full, as either mandated or required fields. There is no requirement to define any new data elements, as all items are currently described in the NHS Data Model and Dictionary.
2.2 Rationale
The Review of Data Security, Consent and Opt-Outs[1] makes the case for commissioners needing high quality linked patient level data, but without the need for patient confidential information. These proposals will allow for accurate linkage of data and patient preferences to be applied, and the consistent application of a pseudonym for commissioning use:
“3.2.30 The third Caldicott principle calls for the minimum amount of personal confidential data to be transferred or accessible as is necessary for a given function to be carried out. That is best achieved by encouraging organisations to switch from using personal confidential data to de-identified data for limited access or anonymised data”.
As per this principle, most commissioning activities can be undertaken in the absence of patient confidential data. However, it is important that certain information is present in all commissioning data flows to ensure that patient objections can be observed and that they are accurately anonymised and can be linked across data sets. Moreover, it is essential that consistent patient, activity and status identifiers are available to commissioners to inform their decision making.
This proposed new Fundamental Information Standard will ensure that the main commissioning data sets (CDS) and other specified national patient-level data sets that flow from providers to NHS Digital, and that used for commissioning purposes within the NHS, contain a consistent set of data items for the following purposes:
1. Enabling NHS Digital to create a consistent commissioning pseudonym for an individual patient in data set records pertaining to that patient. This will be delivered by the patient NHS Number for most records, but will use additional identifiers where the NHS Number is not accurate or available
2. Enabling NHS Digital to disseminate local patient identifiers specific data within patient-level data flows to commissioning data recipients to support invoice validation
3. Enabling NHS Digital to create derivations based on date of birth and postcode of usual address. For example, to calculate the patient’s age at the time of the activity
4. Supplying NHS Digital with derivations based on patient date of birth and postcode of usual address for those patients records where identifiers have been withheld by the provider for legal or other reasons
This will deliver a number of benefits to the NHS commissioning intelligence landscape:
· Improved commissioning decisions for all patient groups.
· Improved use and validation of NHS number and other identifiers
· Improved compliance with legal requirements for anonymisation
· Improved compliance with patient objections
· Improved ability to support integrated care and patient-centric analysis
· Improved efficiency and interoperability of data collection, transmission and analysis
Improving the NHS’ capability to accurately anonymised individuals and calculate derivations will support the NHS’ ability to make decisions based on valid and reliable data to support secondary purposes, such as:
· Planning for future commissioning models (integrated, patient-centric care for example) and developing wider programmes to deliver proactive care for patients
· Supporting contract management processes for commissioned services
· Assessing the success of commissioned services and whether the aims of these services have been met
· Publishing reports on the provision of commissioned services
In addition, there are specific instances where data will need to be re-identified for specific purposes where sufficient legal bases exist (e.g. invoice validation, safeguarding). These consistent identifiers will support the reversal of de-identification to ensure the NHS can be confident that the correct individual has been identified.
Similarly with regards to respecting patient preferences, the NHS must have maximum confidence in its ability to identify individuals within data sets, particularly in instances where the NHS number is not available, to ensure patient objections can be accurately applied.
Aligned to the National Information Board’s Domain H (Data Outcomes for Research and Oversight), the CIDIs will help ensure that innovative analysis of commissioning activities can be properly maintained and supported when the new operating models are in place,and associated IG controls for commissioning data, supported by the NHS Digital Data Services Platform (DSP), becomes operational from April 2017.
Without this standard, there is an increased risk of applying inconsistent pseudonyms to some patients, impacting data quality. Data Services for Commissioners estimates that:
· 200,000 patients a year are unable to supply their demographics or deliberately hide them
· Almost a million are suppressed for changes to identity, Human Immunodeficiency Virus (HIV) and fertility rules, adoption and similar reasons
· Overa million may have out of date information on the Patient Demographic Service (PDS) – for example, homeless, prisoners, armed forces, name changes, people moving General Practitioner etc.
The impact of these patients’ identities being missing disproportionately affects patients from lower income demographics, ethnic minorities and other disadvantaged groups – and this impact may skew commissioning data. We can share the detailed analysis with SCCI members if they request.
2.3 Related Programmes
This request is linked to the National Data Services Development (NDSD) programme and its delivery of the DSP by NHS Digital. The DSP will be used to land, process and disseminate national and local patient-level commissioning data flows.
The Consistent Identification Data Items are designed to support two DSP services:
1. De-identification Service
2. Derivations Service
The DSP de-identification service which will deliver a capability to support anonymisation of patient data in context. This will ensure that specific patient identifiers within in-bound data flows are replaced with a consistent pseudonym for a specific usage context (for example, commissioning). These pseudonyms (called Consistent Commissioning Pseudonyms or CCPs) will be used to link patient-level records within and across data sets during analysis for secondary purposes.
The DSP derivations service will create a number of derivations based on postcode and date of birth as commissioners will usually not be able to receive these identifiers themselves and create the derivations locally.
3 Current SCCI Status
The proposal for this Consistent Identification Data Items information standard was submitted to the NHS England Data Coordination Group (DCG) and approved on 19 April 2016. The assigned reference number is: DCG 16023.
This document is the strategic business justification, which describes the business drivers for the CIDIs and identifies the funding, resources and sponsorship.
3.1 Related Documents
This Business Justification and Funding Statement should be read in conjunction with the following documents:
· SCCI 2210 Consistent Identification Data Items Statement of Need
· SCCI 2210 Consistent Identification Data Items Requirements Specification
· SCCI 2210 Consistent Identification Data Items Communication and Stakeholder Engagement Strategy
· (add other SCCI documents and endorsements)
3.2 Target Implementation Date
The CIDIs ISN needs to align with the National Data Services Development (NDSD) roadmap to deliver de-identification and re-identification functionality for all Data Services for Commissioning Regional Offices (DSCROs) by April 2017 and ensure commissioners can continue to receive patient-level commissioning data following the cessation of Section 251 cover in April 2017. It is acknowledged, however, that compliance will be evolutionary as data sets are created and maintained through the standards process over the next few years.
Insert table to show rough timetable for inclusion of CIDIS in national data sets within scope from April 2017, in line with maintenance strategies
4 Scope
The proposed Consistent Identification Data Items will mandate the collection and submission of a number of key identifiers required to support accurate anonymisation of patient data and the derivation of anonymised metrics. Their scope will be limited to:
· The minimum number of data fields determined to be essential to meet the objectives described above, specific to each data set
· National data sets that have been mandated via an ISN
· Data sets that will receive a commissioning pseudonym and used for commissioning purposes