CQC Adult Inpatient Survey Bespoke HES Extraction

This is a new agreement for Ipsos MORI to obtain record-level pseudonymised Hospital Episode Statistics (HES) Admitted Patient Care (APC) data for a sample of 180,000 individuals who have had their latest spell in hospital between 01/04/2020 and 30/11/2020 (calculated back from 30/11/2020).

The data provided will not be used for contacting patients; only pseudonymised HES data is flowing under this agreement so that a comparison exercise can be carried out to ascertain whether in the future NHS Digital can provide the data required to support the NHS Patient Survey Programme.

Ipsos MORI is the Co-ordination Centre for Mixed Methods for the NHS Patient Survey Programme. These surveys are run on either a yearly or two yearly basis, across all NHS Trusts in England, and are co-ordinated by the Care Quality Commission (CQC). The NHS Patient Survey Programme includes 5 surveys:

1. Adult Inpatients,

2. Maternity,

3. Children and Young People,

4. Urgent & Emergency Care and

5. Community Mental Health.

Currently Ipsos MORI set the survey criteria on behalf of the Care Quality Commission, with individual Trusts commissioning the surveys using one of three private contractors (or a very small number choose to conduct the survey themselves). Data flows to the contractors from Trusts with Ipsos MORI co-ordinating the responses. The Care Quality Commission (CQC) mandates the sample month and the criteria for inclusions.

As a result of the positive experience Ipsos MORI had working with NHS Digital recently requesting data to support the CQC COVID-19 adult inpatient survey and further covid-19 related work, they would like to build on the relationship and work with NHS Digital to reduce burden on Trusts and improve timescales.

CQC wish to utilise NHS Digital to adopt a more centralised approach to their data collection for surveys aiming to use the CQC adult inpatient survey as a litmus test. Centralisation of identification of the cohort with NHSD collecting data for the sample, will reduce the burden on Trusts.

Parallel Run: Ipsos MORI are currently conducting the 2020 Adult Inpatients survey utilising the current method and propose getting a sample from NHS Digital in parallel, following the same processes, to ascertain the impact of the change in methodology:

(SEPARATE PROCESSING TO THIS AGREEMENT) Run 1: The 140/150 Trusts in England provide their sample of 1,250 individuals to their contractors who provide the pseudonymised information to Ipsos MORI.

(THIS AGREEMENT) Run 2: NHS Digital provides Ipsos MORI with the sample of 180,000 record level pseudonymised extract of individuals from the Trusts in England (as per Methodology below).

This will be used for comparisons between the pseudonymised data, to assess comparability between the sample provided by trusts and the sample provided by NHS Digital, to understand any potential impacts on data quality and/or trends by changing sample frame.

The data is used to provide regulation at trust level, so it is vital that there is understanding of any potential impact on trust data to avoid assuming differences are caused by a change in care delivered, rather than a change in the composition of the sample. As there may be specific factors that impact any differences in the sample that we cannot control for and would not know which trusts would be affected by (such as how regularly they update their systems and what type of system they use), using all trusts means we can make sure we are including every factor (which we could not know for sure with a sample) and could identify all trusts affected if there are any differences. This could therefore be taken into account in any year on year and between trust comparisons, to reassure that accurate data is being used for regulation.

The trusts currently pulling the samples is not only an additional burden, but due to the number of trusts drawing individual samples, increases the risk of survey errors, often meaning the data has to be drawn again or (if not identified in time) that that trust does not have comparable results. These errors can relate to misinterpretations of the guidance, errors when implementing the guidance or errors in transferring the file, including section 251 breaches, putting data security at risk. In previous years, trusts have incorrectly excluded certain age groups, or included ineligible patients in their sample, which have then had to be redrawn.

A full list of the errors identified during the Adult Inpatients 2019 survey are available on the NHS Surveys website (https://nhssurveys.org/wp-content/surveys/02-adults-inpatients/04-analysis-reporting/2019/Sampling%20errors%20report.pdf), but these included:

Lookup/sorting errors in the mailing details for two trusts, meaning patients for those trusts received mailings with incorrect names (this was identified during fieldwork, when mailings had already been sent out)

Including maternity patients in the sample, who should be excluded (this sample had to be redrawn)

Excluding patients from a week in the middle of the sampling period, due to a sorting error (this sample had to be redrawn)

Providing outdated CCG coding, which had to be updated

Providing incorrect ICD-10 coding, which had to be updated

Providing incorrect Admission Method Codes, which had to be updated

The Data Controller for this project is CQC and the Data Processor is Ipsos MORI. Ipsos MORI will manage the communication with Trusts on the benefit of the parallel run. CQC will be making final decisions on the use and processing design of the data.

If this works, CQC will consider extending this to the other 4 surveys.

Ipsos MORI are a commercial company charging a fee for its services and if this pilot is successful it will be rolled out more widely which will generate further fees on a wider scale for Ipsos MORI.

LEGAL BASIS

The lawful basis for processing is Article 6(1) (e) - “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”.

CQC͛s remit is to make sure health and social care services provide people with safe, effective, compassionate, high-quality care and CQC encourages them to improve. It does that through effective monitoring and inspection activity underpinned by an Intelligence insight programme that draws together risk and bench marking metrics. Ipsos MORI is the Co-ordination Centre for Mixed Methods for the NHS Patient Survey Programme, coi-ordinated by CQC. For this service evaluation, Ipsos MORI will use data to assess whether the sampling frame could be undertaken by NHS Digital in the future, rather than the sample being selected by individual trusts.

Processing will rely upon item (i) of Article 9(2) as the purpose of the service analysis is to assess the effectiveness and efficiency of using NHS Digital as a centralised data collection and sampling processor in future, offering numerous benefits to the Health and Care system in England - namely to assess whether it would impact the data quality/trends, or whether cost, time and trust burden could be reduced by moving to a centralised sample.

Personal data processed for the purposes of the service evaluation, including special category personal data, will be subject to the provisions of CQC's function under section 48 of the Health and Social Care Act 2008 that permits CQC to conduct any special review or investigation into the provision of NHS care, the commissioning of NHS care, or into the provision of care or services or the exercise of functions by bodies or persons generally or by particular bodies and persons. Care Quality Commission’s (CQC) statutory powers under section 64 (part 1) of the Health and Social Care Act 2008 allow CQC to require information from all registered providers as well as key organisations in the oversight of health and social care; for example, local authorities and NHS Digital (Health and Social Care Information Centre). These powers are constrained by the application of CQC’s Code of Practice for Confidential Personal Information that requires all consideration of the use of (potentially) identifiable data to meet the necessity test.

- NHS Digital Data Production would use the CQC Adult Inpatient Survey filters to obtain a random sample of 1,250 individuals from each of the 140/150 Trusts (a total sample size likely to be around 180,000 individuals) with the "most complete" contact information (this will be done by using the Master Patient Service to verify addresses and mobile numbers). Only if the individual has a verified postal address will they be included in the 1,250 random individuals.

- NHS Digital Data Production links the 180,000 individuals to HES APC to obtain their latest spell only in hospital between 01/04/2020 and 30/11/2020 (calculated back from 30/11/2020), and provides fields requested below in the extract:

o Trust code

o Pseudonymised Patient Record Number (PRN)

o Mobile number indicator

o Year of birth

o Gender

o Ethnic category

o Day of Admission

o Month of Admission

o Year of Admission

o Day of Discharge

o Month of Discharge

o Year of Discharge

o Length of Stay

o Treatment Function Code (on discharge)

o ICD-10 Chapter Code - This should be the chapter code (in roman numbers e.g. XVIII or V) for the primary diagnosis on discharge – so there should only be one code per person and they should match the roman numbers as here: https://icd.who.int/browse10/2019/en#/

o CCG

o Treatment Centre Admission

o Admission method

o NHS Site code-Admitted

o NHS Site code-Discharged

o COVID-19 diagnosis

• Trust codes need to be 3 digits; if more than that, then take the first 3 digits only

(COVID-19 diagnosis will be split as follows:

1 - ICD-10 code U071 – if U071 at any time during a patient’s spell in hospital.

2 - ICD-10 code U072 – if no U071 code, but a U072 code at any time during the spell in hospital.

3 - Not including any of the above - if neither U071 code or U072 code at any point.)

- NHS Digital Data Production will then disseminated this record level pseudonymised data extract to Ipsos MORI via Secure Electronic File Transfer Service (SEFT).

CQC will not have access to any pseudonymised data under this service evaluation. No attempt to re-identify individuals will be made by the Data Processor. All outputs must be aggregated with small number suppression applied as per the HES Analysis Guide. The data will not be linked to any other datasets.

All pseudonymised data will be saved encrypted and password protected, on the Ipsos MORI server, with access given to the project team only. All project team members are substantive members staff employed by Ipsos MORI. They are required to abide to Ipsos MORI policies on information security, data protection and physical security and have received training on these. Ipsos MORI will process and store the data sets provided by NHS Digital in line with these policies.

HES DISCLOSURE CONTROL / SMALL NUMBER SUPPRESSION

In order to protect patient confidentiality, when presenting results calculated from HES record level data, outputs will contain only aggregate level data with small numbers suppressed in line with HES Analysis Guide. When publishing HES data, you must make sure that:

· cell values from 1 to 7 are suppressed at a local level to prevent possible identification of individuals from small counts within the table.

· Zeros (0) do not need to be suppressed.

· All other counts will be rounded to the nearest 5.

Data will not be made available to any third parties other than those specified except in the form of aggregated outputs with small numbers suppressed in line with the HES Analysis Guide.

A written report will be produced by Summer 2021, with aggregated and suppressed comparisons between the trust provided sample and the NHS Digital sample, as well as details on any potential impact on the process or survey results.

All outputs will be aggregated with small number suppression applied as per the HES Analysis Guide

This is likely to be published on the National Patient Survey Programme website, and shared with NHS trusts, contractors and stakeholders as part of any decision to move to a centralised sample.

The National Patient Survey Programme (NPSP) provides patient experience data for trusts across England, to facilitate service improvement and to support the Care Quality Commission (CQC) with healthcare regulation. Ensuring that the data provided by this programme is high quality and that any impacts on trends are understood is vital to ensuring that these processes are effective. Therefore, it is important that any change to the process is fully tested.

If it is possible to move to a centralised sampling approach, this could have the following potential benefits:

1) Reduction of burden to trusts

Currently, every NHS trust in England has to provide their own sample for each of the survey in the NPSP, which is a burden among already busy data processing staff at each trust. As each sample is drawn separately, any data queries also have to be dealt with by the trust, which is an additional burden. Particularly in the current situation, reducing the amount of work required by each trust is a particular benefit, and also means that the survey is not reliant on trusts having the staff time (the Maternity 2020 survey had to be cancelled in part due to trusts not being able to provide samples, meaning data from that year is not available for that survey).

2) A consistent approach for data collection

As each trust draws their own sample, this introduces several opportunities for variation. Trusts are selecting samples at different times, and entering field at different times, leading to different fieldwork lengths. It also introduces the risk of different trusts understanding the rules differently, and although processes are in place to reduce this risk, selecting centralised samples would eliminate this risk altogether. By ensuring as much comparability between trusts as possible, it ensures that the results are better able to measure variation in experience between trusts and know this is true variation and not the result of sampling differences.

3) Potential cost saving and reducing time from hospital episode to publication of results

By centralising the sample, there is potential to reduce costs and the associated time involved by minimising the number of samples that need to be individually checked from over 100 to 1. The trusts pay costs for contractors to conduct their surveys, and the CQC pay for the coordination centre to review, and both of these costs have the possibility to reduce if the sample is centralised. There is also potential to reduce the time from the hospital episode to the publication of the results, by potentially shortening the sample period (as some trusts take a longer time than others to produce their sample) and reducing the fieldwork period (as this is currently longer to account for some trusts going into field later than others). As part of this piece of work, the potential implications on the survey timings and costs will also be reviewed.

4) Reducing the risk of data breaches

At the moment, as each sample is drawn by the individual trust, each sample needs to be individually securely transferred to a contractor, separated from the mailing data, and then a pseudonymised version of each individual sample shared with the co-ordination centre for checking. As this is a large number of individual data transfers, it increases the risk of data breaches, where data may not be shared securely or may include details that should not be shared with the recipient. Although there are processes in place to reduce this risk, reducing the number of data transfers reduces the risk of these breaches happening.

Yielded Benefits is not a requirement for new applications.