National Update: The
information revolution and
the 2012 Caldicott Review
Simon Richardson – Information Rights Manager
The Information Revolution
Source: www.freeimages.co.uk
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Background
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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?
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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:
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‘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
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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
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