DSfC - NHS Gloucestershire CCG - RS & IV

Invoice Validation

Invoice validation is part of a process by which providers of care or services get paid for the work they do.

Invoices are submitted to the Clinical Commissioning Group (CCG) so they are able to ensure that the activity claimed for each patient is their responsibility. This is done by processing and analysing Secondary User Services (SUS+) and Personal Demographic (PDS) data, which is received into a secure Controlled Environment for Finance (CEfF). The SUS+ and PDS data is identifiable and is only used to confirm the accuracy of backing-data sets (data from providers) and determining if the CCG is the responsible commissioner for the patient.

The NHS number is only used to confirm the accuracy of backing-data sets and will not be used further.

The CCG are advised by the appointed CEfF whether payment for invoices can be made or not.

Invoice Validation with be conducted by the CCG

Risk Stratification

Risk stratification is a tool for identifying and predicting which patients are at high risk or are likely to be at high risk and prioritising the management of their care in order to prevent worse outcomes.

To conduct risk stratification Secondary User Services (SUS+) data, identifiable at the level of NHS number is linked with Primary Care data (from GPs) and an algorithm is applied to produce risk scores. Risk Stratification provides focus for future demands by enabling commissioners to prepare plans for both individual and groups of vulnerable patients. Commissioners can then prepare plans for patients who may require high levels of care. Risk Stratification also enables General Practitioners (GPs) to better target intervention in Primary Care.

Risk Stratification will be conducted by South, Central and West Commissioning Support Unit and Sollis Partnership Ltd.

Cloud2 Limited will be assisting in the set up and delivery of Power BI Implementation and are therefore listed as a data processor.

NHS Gloucestershire CCG utilise both Microsoft Limited and Amazon Web Services for the provision of cloud storage services. Microsoft Limited are commissioned to support development and maintenance of Power BI reporting, whilst Amazon Web Services provide the wider cloud storage services for data held by the CCG.

PROCESSING CONDITIONS:

Data must only be used for the purposes stipulated within this Data Sharing Agreement. Any additional disclosure / publication will require further approval from NHS Digital.

Data Processors must only act upon specific instructions from the Data Controller.

Data can only be stored at the addresses listed under storage addresses.

All access to data is managed under Role-Based Access Controls. Users can only access data authorised by their role and the tasks that they are required to undertake.

Patient level data will not be linked other than as specifically detailed within this Data Sharing Agreement. Data released will only be shared with those parties listed and will only be used for the purposes laid out in the application/agreement.

NHS Digital reminds all organisations party to this agreement of the need to comply with the Data Sharing Framework Contract requirements, including those regarding the use (and purposes of that use) by “Personnel” (as defined within the Data Sharing Framework Contract ie: employees, agents and contractors of the Data Recipient who may have access to that data)

The DSCRO (part of NHS Digital) will apply National Opt-outs before any identifiable data leaves the DSCRO only for the purpose of Risk Stratification.

CCGs should work with general practices within their CCG to help them fulfil data controller responsibilities regarding flow of identifiable data into risk stratification tools.

The identifier available in the data set is the NHS numbers. Any further identification of the patients will only be completed by the patient’s clinician on their own systems for the purpose of direct care with a legitimate relationship.

ONWARD SHARING:

In the development of cohorts of pseudonymised patients considered to be at risk, the data controllers may need the facility to provide identifiable results back to direct health or care professionals for the purpose of direct care. Additionally clinicians, made aware of a number of cases that they believe would need intervention may request re-identification for that direct care purpose. These instances of re-identification will generally be carried out as programmes of work or, rarely, on an individual/small group basis.

NHS Digital provides a re-identification service for this process. All re-id requests will be processed and authorised by NHS Digital on a case by case basis. National data opt outs are not applied in these cases as they are for the purposes of direct care which follows the legal basis of implied consent.

The following are typical examples of instances where a CCG might want to use the re-identification process:

A&E High Attendance usage

The CCG can filter data to show for example the number of A&E attendances in a given period for each patient. The CCG can then flag to the relevant GP of the patient any patients that require intervention. An outcome of this is earlier intervention in the patient(s) care thus potentially reducing future costs and minimising future risk.

Polypharmacy re-IDs

CCGs can request re-ID of a list of patients to be sent to the relevant GP with a high number of medications (ingredient count) and review the medication for these patients. This can help address the risk of polypharmacy which is recognised as an adverse risk factor for patient safety. A by-product of such reviews may be to reduce costs of medication.

The Re-identification process for direct care is as follows:

1. The CCG identifies a patient cohort to be re-identified for the purpose of direct care.

2. The CCG sends a re-id request to the DSCRO. This may be done through the CCG or CSU’s Business Intelligence (BI) Tool, or through a manual form.

3. The DSCRO assesses as to whether the request passes the specified re-identification process checks. Checks include if the requester is authorised to access identifiable data, if the number of patients in the cohort is appropriate, and that the request does not seem inappropriate or outside of expected parameters, including for example around timings and the requestor’s relationship with patients in the data. These checks are carried out either by DSCRO staff using pre-approved information (timing’s, requester’s identity etc) or via an automated system.

4. For automated systems, steps 1 - 3 wouldn’t apply in most cases as it would be the direct care professional who identifies the cohort and as long as they are an approved re-id user and have gone through security checks initially, they will be able to re-id without further checks.

5. If successful/approved, the DSCRO re-identifies the relevant data item(s) for the appropriate patients and returns the identifiable fields to Health or Care professional(s) with a legitimate relationship to the patient. The CCG does not see the identifiable record.

6. DSCROs retain an audit trail of all re-id requests

Aggregated reports only with small number suppression can be shared externally as set out within NHS Digital guidance applicable to each data set.

SEGREGATION:

Where the Data Processor and/or the Data Controller hold both identifiable and pseudonymised data, the data will be held separately so data cannot be linked.

Where the Data Processor and/or the Data Controller hold identifiable data with opt outs applied and identifiable data with opt outs not applied, the data will be held separately so data cannot be linked.

All access to data is auditable by NHS Digital.

Data for the purpose of Invoice Validation is kept within the CEfF, and only used by staff properly trained and authorised for the activity. Only CEfF staff are able to access data in the CEfF and only CEfF staff operate the invoice validation process within the CEfF. Data flows directly in to the CEfF from the DSCRO and from the providers – it does not flow through any other processors.

DATA MINIMISATION:

Data Minimisation in relation to the data sets listed within the application are listed below. This also includes the purpose on which they would be applied -

For the purpose of Risk Stratification:

- Patients who are normally registered and/or resident within the Gloucestershire CCG region (including historical activity where the patient was previously registered or resident in another commissioner

For the purpose of Invoice Validation:

- Patients who are resident and/or registered within the CCG region.

Microsoft Limited provide Cloud Services for South Central and West Commissioning Support Unit and NHS Gloucestershire CCG and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.

Amazon Web Services provide Cloud Services for NHS Gloucestershire CCG and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.

ANS Group Limited will be assisting in the set up and management of the South Central and West Commissioning Support Unit Microsoft Azure Cloud and are therefore listed as a data processor. They will not have any additional processing / storage addresses (as these will be the Microsoft Azure addresses). Using the data for any other purpose would be considered a breach of this agreement.

University Hospitals Bristol NHS Foundation Trust do not access data held under this agreement as they only supply the building. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.

Gloucestershire Hospitals NHS Foundation Trust provide IT infrastructure support to the CCG and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.

Invoice Validation

Data Processor(s) - NHS Gloucestershire CCG

1. Identifiable SUS+ and PDS Data is obtained from the SUS+ Repository by the Data Services for Commissioners Regional Office (DSCRO).

2. The DSCRO pushes a one-way data flow of SUS+ and PDS data into the Controlled Environment for Finance (CEfF) located in the CCG.

3. The CEfF also receive backing data from the provider.

4. The CEfF conduct the following processing activities for invoice validation purposes:

a. Validating that the Clinical Commissioning Group are responsible for payment for the care of the individual by using SUS+ and PDS and/or provider backing flow data.

b. Once the provider backing information is received, it will be checked against national NHS and local commissioning policies, as well as being checked against system access and reports provided by NHS Digital to confirm the payments are:

i. In line with Payment by Results tariffs

ii. In relation to a patient registered with the CCG, GP or resident within the CCG area.

5. The CCG are notified by the CEfF that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved.

Risk Stratification - Data Processor(s) - South, Central and West Commissioning Support Unit and The Sollis

Partnership Ltd

1. Identifiable SUS+ data is obtained from the SUS Repository to the Data Services for Commissioners Regional Office (DSCRO).

2. Data quality management and standardisation of data is completed by the DSCRO and the data identifiable at the level of NHS number is transferred securely to South, Central and West Commissioning Support Unit, hosted, Sollis Partnership Ltd managed, who securely hold the SUS+ data.

3. Identifiable GP Data from the GP system to South, Central and West Commissioning Support Unit hosted, Sollis Partnership Ltd managed, processing area within the secure Data Centre

4. SUS+ data is linked to GP data in the risk stratification tool by Sollis Partnership Ltd within the South, Central and West Commissioning Support Unit hosted, Sollis Partnership Ltd managed, processing area

5. The Sollis Partnership Ltd access the risk stratification tool via remote role-based access controls and manage the risk stratification.

6. As part of the risk stratification processing activity, GPs have access to the risk stratification tool within the data

processor, which highlights patients with whom the GP has a legitimate relationship and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.

7. Once the Sollis Partnership Ltd has completed the processing within the South, Central and West Commissioning Support Unit environment, the CCG can access the online system via a secure connection to access the data pseudonymised at patient level and aggregate with small number suppression.

8. A pseudonymised version of the risk stratification database will be securely transferred from the South, Central and West Commissioning Support Unit to the CCG data warehouse undertaken by the South, Central and West Commissioning Support Unit.

9. Cloud2 Limited will access this data warehouse to assist in the setup and delivery of Power BI reports.

Cloud 2 Limited will only access the data via a NHS Gloucestershire CCG encrypted laptop. They will not have any additional processing /storage addresses and will not be storing data outside of the GCCG infrastructure. Using the data for any other purpose would be considered a breach of this agreement.

No data is stored at Sollis Partnership Ltd addresses. Sollis Partnership Ltd employees have remote access from the address provided to a secure area at South Central and West Commissioning Support Unit to identifiable data supplied by the DSCRO for the purpose of Risk Stratification only. Data is not taken from the secure server and is worked on within the CSU environment remotely.

INVOICE VALIDATION

1. The Controlled Environment for Finance (CEfF) will enable the CCG to challenge invoices and raise discrepancies and disputes.

2. Outputs from the CEfF will enable accurate production of budget reports, which will:

a. Assist in addressing poor quality data issues

b. Assist in business intelligence

3. Validation of invoices for non-contracted events where a service delivered to a patient by a provider that does not have a written contract with the patients responsible commissioner, but does have a written contract with another NHS commissioner/s.

4. Budget control of the CCG.

5. Support validating financial payments for contracted and non-contracted activity, determining if the CCG is the responsible commissioner for the patient.

RISK STRATIFICATION

1. As part of the risk stratification processing activity detailed above, GPs have access to the risk stratification tool which highlights patients for whom the GP is responsible and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.

2. GP Practices will be able to view the risk scores for individual patients with the ability to display the underlying SUS+ data for the individual patients when it is required for direct care purposes by someone who has a legitimate relationship with the patient.

CCGs will be able to:

3. Target specific vulnerable patient groups and enable clinicians with the duty of care for the patient to offer appropriate interventions.

4. Reduce hospital readmissions and targeting clinical interventions to high risk patients.

5. Identify patients at risk of deterioration and providing effective care.

6. Reduce in the difference in the quality of care between those with the best and worst outcomes.

7. Re-design care to reduce admissions.

8. Set up capitated budgets - budgets based on care provided to the specific population.

9. Identify health determinants of risk of admission to hospital, or other adverse care outcomes.

10. Monitor vulnerable groups of patients including but not limited to frailty, COPD, Diabetes, elderly.

11. Health needs assessments - identifying numbers of patients with specific health conditions or combination of

conditions.

12. Classify vulnerable groups based on: disease profiles; conditions currently being treated; current service use; pharmacy use and risk of future overall cost.

13. Production of Theographs - a visual timeline of a patients encounters with hospital providers.

14. Analyse based on specific diseases

In addition:

- The risk stratification tool will provide aggregate reporting of number and percentage of population found to be at risk.

- Record level output (pseudonymised) will be available for commissioners (of the CCG), pseudonymised at patient level.

Onward sharing of this data is not permitted.

INVOICE VALIDATION

The invoice validation process supports the ongoing delivery of patient care across the NHS and the CCG region by:

1. Ensuring that activity is fully financially validated.

2. Ensuring that service providers are accurately paid for the patients treatment.

3. Enabling services to be planned, commissioned, managed, and subjected to financial control.

4. Enabling commissioners to confirm that they are paying appropriately for treatment of patients for whom they

are responsible.

5. Fulfilling commissioners duties to fiscal probity and scrutiny.

6. Ensuring full financial accountability for relevant organisations.

7. Ensuring robust commissioning and performance management.

8. Ensuring commissioning objectives do not compromise patient confidentiality.

9. Ensuring the avoidance of misappropriation of public funds.

RISK STRATIFICATION

Risk stratification promotes improved case management in primary care and will lead to the following benefits

being realised:

1. Improved planning by better understanding patient flows through the healthcare system, thus allowing commissioners to design appropriate pathways to improve patient flow and allowing commissioners to identify priorities and identify plans to address these.

2. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services thus allowing early intervention.

3. Improved access to services by identifying which services may be in demand but have poor access, and from this identify areas where improvement is required.

4. Supports the commissioner to meets its requirement to reduce premature mortality in line with the CCG Outcome Framework by allowing for more targeted intervention in primary care.

5. Better understanding of local population characteristics through analysis of their health and healthcare outcomes

All of the above lead to improved patient experience and health outcomes through more effective commissioning of services.

The continued access to this data will enable the CCG to ensure providers are correctly paid for the care they deliver and that high risk patients are target to health care professionals to prevent worse outcomes

The CCG has produced an annual report which includes reference to key achievements and developments, for which processing of NHS Digital data has supported.

The report can be found at: https://www.gloucestershireccg.nhs.uk/about-us/publications/annual-reports/