COVID Data Sharing Measures – No. 19

COVID Data Sharing Measures – No. 19

Updated 09.06.20 with advice on:

  • Managing Shielded Patients and notification of suspected COVID cases

 

Notification of suspected COVID cases

COVID is a notifiable illness. Regulations state that clinicians should not wait for laboratory confirmation before notifying. Laboratory confirmed cases are notified centrally. However since Jan 2020 the low threashold for suspicion (anyone with cough or sore throat and symptoms of fever etc) has meant that there will be large numbers of suspected cases. Notifying this group whilst officially required is not likely to be a helpful process.

This has been discussed with senior clinicians at Public Health England (PHE) who understand and agree there is a dilemma. Because COVID is a notifiable illness they have no choice but to make the request – but accept that the information is of limited value and that this would not be best use of primary care time. A request to review this policy has been “passed up the chain”. In the meantime, practices can either wait until there has been a response, or if they wish to fulfil the legal obligations they can send PHE a spread sheet with the relevant details. (Our practice has collected the data, but has decided to wait for further information before notifying suspected COVID cases).

 

Updated 28.05.20 with advice on:

  • GP Connect (NWL considerations)
  • Summary Care Record (action needed on Fair Process Notifications)
  • COVID data managed by WSIC
  • Managing Shielded Patients and using COVID templates
  • Medopad App use int Respiratory Hubs

 

GP Connect

COVID measures have been taken to improve the access for health and care professionals to medical records and information. This will support safe treatment and advise to patients who have called NHS 111, or are receiving care in settings other than general practice.  The advice below has been précised from the letter sent to all GPs by HNSX and also includes information specific for NWL practices

GP Connect allows authorised clinical staff in general practice, NHS 111 and other care settings providing direct care, to view clinical information from a patient’s GP record by providing a read only HTLM view of the full GP record. It also supports the sharing of booked patient appointments. This functionality has been authorised by NHS Digital for all GP practices in England and will be enabled by GP system suppliers. Opt-outs where patients have made them will be respected

These changes will:

  • improve GPs ability to treat patients outside of their registered practice, giving patients easier access to a GP when they need one, regardless of demand or staffing levels in their own practice, for example within a network or a federation hub;
  • give authorised health and care professionals working in primary care, NHS 111 – including the COVID Clinical Assessment Service (CCAS) – and other appropriate direct care settings, access to the GP records of the patients they are treating, regardless of where they are registered; and
  • allow remote organisations such as NHS 111 to book appointments directly with the patient’s GP practice including the ability to manage referrals from the COVID Clinical Assessment Service (CCAS). This will enable healthcare professionals to provide more timely care and provide flexibility for the primary care system.

 

Actions which NWL GP Practices need to take

So as not to require practices to set up GP connect service individually NHS Digital have implemented a national roll out, which will be managed by the GP system suppliers for ALL GP Surgeries and GP led hubs. GP practices will still be required to implement some changes to allow the remote booking of appointments into their clinical systems and further details will be provided when this is required.

NWL already has a system for the allocation of remote bookings and in the short term this is fit for purpose and will remain the booking mechanism in place. We are piloting the GP Connect remote booking system in several practices and will inform GP when the GPC booking component will be widely rolled out. In the interim, practices do not need to make changes.

Legal basis for this action

This action is being taken in response to the Notice issued on 20th March 2020 under Regulation 3(4) of the Health Service Control of Patient Information Regulations 2002 requiring confidential patient information to be shared in the circumstances set out in the Notice.

The changes will remain in force during the period of the COVID-19 emergency period as set out in the Notice (unless extended or reduced) at which point systems will return to their current state unless alternative arrangements have been put in place before then.

To remove uncertainty over the effect of the Notice, NSHX have written to the GP system suppliers to request them to enable these changes without further instruction from GP practices. Your GP system suppliers should inform you in advance of making these changes, so that their role in facilitating these changes is made clear to you.

Safeguards required to keep information safe have not been compromised. Practices do not need to change any existing Data Sharing Agreements in relation to COPI legislation. However, in consideration of the possible longer-term implementation of GP Connect we have written a DPIA for consider the risks and mitigations and are considering incorporating the use of GP connect in existing data sharing agreements. The BMA and RCGP are supportive of this work, as are the Information Commissioner’s Office and the National Data Guardian.

Further information including statements from those bodies is available on the following webpage https://www.nhsx.nhs.uk/covid-19-response/data-and-information-governance/howdata-supporting-covid-19-response/

Questions can be directed to out NWL IG team or directly  NHSX: digitalprimarycareengland@nhsx.nhs.uk

Further plans for GP Connect

COPI legislation covers the use of the GP Connect data for COVID use until the 20th Sep 2020. We anticipate the possibility of continuing to use GP Connect beyond COVID and the NWL  DPIA which has been written to support this is below:

NWL GP Connect DPIA

We are also writing up an information sharing agreement to accommodate that scenario, which will either be a separate ISA or will be incorporated into our existing sharing agreement for direct care 

Summary Care Record (SCR) changes:

As part of COVID measures to support patient care, the default SCR consent has changed from, implied consent to meds allergies and adverse reactions, to implied consent for meds, allergies, adverse reactions and additional information.

The current view in SystmOne can be found through the left sided admin menu tab under Spine Details and SCR Details

There is an equivalent process in EMIS (below):

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Patients can still give their express consent / dissent to any of the last three tick box options below. If patients choose “express consent for medication and allergies and adverse reactions only” this will trump the new implied consent settings. Patient choices can be mediated through their GP practice by verbal request, or via a form.

Action required:

To inform your patients about these measures please ensure that your FPNs contain a section under Summary Care Record which points to: Supplementary Privacy Notice for Summary Care Records

 COVID datasets for WSIC:

WSIC are working towards getting daily GP data from Discovery Data Services (DDS)

  • An email explaining that data will be flowing to DDS from which WSIC would extract data has been sent to all the Caldicott guardians/contacts for NWL practices registered on the Data Controller Console (DCC).
  • So far just 220/357 practices are signed up to the daily data processed extracted through DDS
  • WCSIC also continue to work with the fortnightly data feeds from Apollo to produce COVID dashboards for the sector

 

The specific COVID-19 datasets that WSIC have secured since the beginning of April are:

  • Full NWL population data from NHS digital with patient identifiable information – Frequency monthly
  • Direct admission data from all the acute trusts with confirmed/suspected COVID patients, this include the bed status i.e. critical care and ventilation details (fully patient identifiable)– Frequency daily
  • Full patient identifiable data from CMC with details of advanced care plan, resuscitation preference etc. – Frequency fortnightly
  • Direct pathology results data from all the pathology providers with full patient identifiable information – Frequency 3 times daily
  • The shielded patients list from NHS digital with patient identifiable information – Frequency weekly

 

The above datasets have been linked with the existing WSIC datasets to generate COVID dashboards. The dashboards allow the viewing of Personal Identifiable Data to NWL clinicians using Role Based Access Control who have a legitimate relationship with any identified patient. Healthcare professionals who do not have a legitimate relationship with patient can only see aggregate data.  WSIC have updated their website with the details – https://www.healthiernorthwestlondon.nhs.uk/news-resources/information-sharing/covid-0 and have also included this information in the newsletter that has been sent to all users with a registered login to WSIC.

WSIC does not extract appointment data, but they do also have a separate BI function which undertakes sector analysis for the ‘gold command’ which has been established for COVID management support. This central BI team do not have the access to receive/view/process patient identifiable information, but they do see the output from TPP trust-wide reporting unit and EMIS search and report modules. This does not contain any PID and is at an aggregate level. That BI team does not have the direct control over Brent and Harrow EMIS search and report and has to get permission from the relevant CCG to run the searches if required.

GPES data collection

The General Practice Extraction Service (GPES) collects information for a wide range of purposes, including providing GP payments. It works with the Calculating Quality Reporting Service (CQRS) and GP clinical systems as part of the GP Collections service.

Coronavirus (COVID-19) has led to increased demand on general practices, including an increasing number of requests to provide patient data to inform planning and support vital research on the cause, effects, treatments and outcomes for patients of the virus.  To support the response to the coronavirus outbreak, NHS Digital has been legally directed to collect and analyse healthcare information about patients, including from their GP record, for the duration of the coronavirus emergency period.

This General Practice Extraction Service (GPES) data will be extracted as a snapshot in time extract on the initial collection. A subsequent fortnightly extraction will then continue until the expiry of the COVID-19 Direction. This has been in place since 31 March 2020 but will be reviewed in September 2020 and every six months thereafter. The frequency of the data extraction may change in response to demand.

Action required:

GPs must sign up to this extraction, and this is not a request it is a legal requirement.

See the following NHS Digital Notice:

See also this helpful LMC article:  https://www.lmc.org.uk/article.php?group_id=23474

Managing Shielded patients:

There is a central register of patients who are at the the highest risk of serious health complication in the event of getting COVID. GPs have control over who is on this list and can add patients by coding them in to High, Moderate, or Low risk.

Once they have been entered into the GP clinical system, these codes will be extracted weekly to update the central register.

To add patient to the high-risk group enter the high risk code. For patients who are already in the high-risk group but their GP thinks they should not be, entering the moderate risk code will automatically remove them from the high risk group (when the weekly data extraction occurs). The moderate risk group should be identical to your flu vaccination cohort.  Patients not significantly at risk, and who do not need yearly flu jabs, can be coded as low risk.

Letters to patients.

Patients identified as high risk in the first assessment have been sent a standard letter by NHS digital (see below).  Patients can be added to the high risk group through two other mechanisms.

  • Recommendation by secondary care consultants
  • Self inclusion (patients may write to their GPs asking to be included on the high risk list).

In general there is an expectation that the list from secondary care will be considered and accurate (although lists received to date have not always specified the reason for inclusion). However in both cases GPs can exercise discretion and should make the final decision. Patients who have not previously been on the list and are added should be sent the standard letter:

  1. Standard inclusion on high risk list (updated May 2020)
  2. Removal from high risk group where not indicated
  3. Non-inclusion in high risk group after self-nomination

It is good practice to discuss in person with patients if you think they should not be on the list, or indeed with those patients who do not want to be included. Patients in groups 2) and 3)  who are being removed, or not included despite a request may also require a letter at their GP’s discretion.

Action required:

Aside from those written to by NHS digital, the responsibility of notifying patients about inclusion on the high risk list will rest with the GP practice.

Resources for managing shielded patients and COVID:

COVID templates

In addition, templates are available in your clinical systems which will allow you to enter the relevant clinical codes for COVID and to support and manage the follow up of high risk and shielded patients.

The description below covers use in SystmOne TPP (there are equivalent templates in EMIS). The COVID icon is a yellow triangle with an exclamation mark

and can be seen in the top right hand window below the patient demographics. It is also present on the patient home page.

 

 

 

 

 

Clicking this icon will bring up the COVID template which supports the recording of coded COVID information such as symptoms, findings and diagnosis.

There are other tabs which allow the documentation of management plans, the identification of useful resources, the recording information on other respiratory conditions etc. which will not be further detailed here.

Within the COVID template you will see another yellow triangle Icon labelled ‘Welfare template’. Clicking on this will bring up the following template.

This can be used by receptionist, HCAs or other trained staff to call patients in your high risk groups (or in those who you have identified as having moderate COVID related symptoms) for follow up. The main section is the central grey window which contains a number of simple tick box questions.  Once these have been completed the pink social assessment box can be ticked. If any needs have been identified your staff can forward this information by ‘tasking’ the relevant person (GP, Nurse, Link worker etc.). Note there are other potentially useful tabs  within the template which will not be detailed here.

 Medopad:

Another NWL COVID measure has been to look at ways of managing people in their own home. NHSX is supporting a pilot which uses a Medopad App (a remote monitoring product) across ‘Respiratory Hubs’ in North West London.

The App has been developed to manage and remotely monitor patients with confirmed and suspected COVID-19 infections who are self-isolating. The aim is to keep them out of hospital and deliver their care in a home environment. Healthcare staff at respiratory hubs will identify suitable patients and give them instructions about how to download and use the app. They may also be provided with a pulse oximeter. At set intervals they will be asked to record specific clinical information such as:

  • Symptoms
  • Temperature
  • Heart rate
  • Respiratory Rate
  • Oxygen saturation

There may later be the potential for them to be monitored remotely via a ‘virtual ward’ and for this information to be available through patient dashboards. The pilots will run for 3-6 months after which an evaluation will review the impact of this intervention consider the benefits of a wider roll out.

x

Updated 17.04.20 with advice on Fair Process Notification

Sharing for Direct Care

To support routine and emergency care during the COVID-19 crisis we are taking measures across NWL to share access to GP patient records more widely. This will be done by extending smart card permissions to existing authorised and trained staff in a staged manner*:

  1. Sharing will extend initially from the registered GP to Primary Care Networks.
  2. This may later be further extended to allow CCG wide access or
  3. In the event of worsening crisis to allow access by trained staff across NWL

x

* with the exception of Brent where Harness have requested an earlier migration towards sharing at CCG level

x

Caldicott Guardians from each practice have been asked to:
  1. Sign a bulk RA02 process, allowing shared smartcard access to their clinical systems by suitably qualified staff.
  2. Nominate members of their practice to contribute to this pool of staff and to vouch that they:
  • have had clinical training and are competent to exercise the permissions on their smart cards
  • have had IG training and understand their professional and legal responsibilities of confidence to their patients**
  • have a contractual relationship with the nominating Caldicott Guardian.

**

** In particular that access to patient records requires the existence of a legitimate relationship (i.e. they must be providing that patient with care) and that inappropriate access to records is a serious and dismissible offence.

 

Sharing data to plan and provide care in the Covid pandemic

The Secretary of State for Health has issued a notice under the ‘Control of Patient Information’ regulations (COPI)1  authorising NHS Digital to disseminate information to approved organisations in order to help them to effectively tackle the pandemic. These measure will be in place until the 30th Sep 2020 and will be reviewed at that time. This legal purpose will be used within the WSIC when identifying data to support the planning and delivery of health care related to COVID-19

National shielding measures require a coded list of patients at highest clinical risk from COVID-19 (a subset of the flu jab cohort) to be extracted from GP clinical systems through GPES in the week starting 13th April. These patients will be written to by the NHS with specific advice. See update with a link to the original communication and FAQ sent on the 3rd April.

x

Fair Process Notification amendments

Because of the above changes we are advising all practices to amend their FPNs. You may choose to insert the paragraph below which covers patient information for COVID measures in hub and non-hub GP practices (or you may prefer a suitable alternative if your data sharing circumstances differ) :

 Data Sharing Measure in relation to the COVID pandemic

1)      The secretary of state has served notice under the Health Service COPI (Control of Patient Information) Regulations 2002 to require organisations to process confidential patient information during the COVID Pandemic and these measures will remain in place until September 2020. In addition, aggregate data which supports the planning and delivery of health care during the COVID pandemic will be processed securely through the Whole Systems Integrated Care database. Any such data will be formally identified as COVID related and used only for this purpose until Sep 2020.

2)      Primary care staff across each CCG will be able to access your full medical record without consent during the COVID-19 pandemic but will only do so when this is necessary to provide you with care. They will be required to use a smartcard which confirms their identity, and which limits their access and actions to those appropriate for their role. They will all have been trained to understand their professional and legal responsibilities in providing you with care. Access to records by trained clinicians will be made available for example when patients:

  • are asked to present to the Respiratory Hubs offering care for COVID related illness
  • are directed to other hubs based services for routine face to face, or telephone or video consultation
  • require community visiting services

3)      The extension to smart card permissions is currently limited to CCG wide sharing, but in the event of the pandemic escalating we have taken measures to implement NWL wide sharing and will notify patients through this Fair Processing Notice, should that need arise.

4)   The government have requested reinstatement of the “break glass” facility” previously available in TPP clinical systems so as to allow a declared access to patient records in the event of an emergency.

 

Questions about COVID and data sharing

 

Above table as a word document

 

Reinstated ‘Break Glass’ Functionality in TPP

TPP has received a direction from Dame Fiona Caldicott (National Data Guardian) to reinstate the consent override (break glass) function within SystmOne.

The key points are:

  • This is for direct care only
  • Anyone using it must take advice from their DPO and Caldicott Guardian
  • It should be use only by registered and regulated health and care professionals
  • Every effort must be made to keep patients informed
  • A monthly audit of use will be sent to the NDG, ICO, NHS D ad NHSX
  • This instruction will be in effect for 3 months from 30/3/2020

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The NWL local policy is:

  • Use access as normal within our local EDSM allowed list
  • If access is required from outside this locality use the agreed EDSM process to obtain a validated password
  • If this does not work of if there is a reason that a clinician needs access to the notes in the absence of the patient then the break glass facility can be used (noting the above points)

 

 

 


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