DSfC - NHS South Warwickshire CCG; IV

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 the CCG is able to ensure that the activity claimed for each patient is their responsibility. This is done by processing and analysing Secondary User Services (SUS+) data, which is received into a secure Controlled Environment for Finance (CEfF). The SUS+ data is identifiable at the level of NHS number. The NHS number is only used to confirm the accuracy of backing-data sets (data from providers) and will not be used further.

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

Liaison Financial Services conduct an independent ad-hoc review on retrospective payments made. Investing resource, skills and experience into deeper reconciliation, this identifies overcharges already paid and recovers savings for the CCG that would otherwise be lost.

Invoice Validation will be conducted by Arden and GEM Commissioning Support Unit and Liaison Financial Services.

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)

ONWARD SHARING:

Patient level data will not be shared outside of the CCG unless it is for the purpose of Direct Care, where it may be shared only with those health professionals who have a legitimate relationship with the patient and a legitimate reason to access the data.

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 Invoice Validation:

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

Coventry and Warwickshire Partnership NHS Trust supply IT infrastructure for 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.

NHS Midlands and Lancashire Commissioning Support Unit and Greater Manchester Shared Services (hosted by NHS Oldham CCG) supply IT infrastructure for Arden and GEM Commissioning Support Unit and are therefore listed as data processors. 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.

Ilkeston Community Hospital 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.

Microsoft UK supply provide Cloud Services for Liaison Financial Services Ltd 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 - Arden and GEM Commissioning Support Unit

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

2. The DSCRO pushes a one-way data flow of SUS+ data into the Controlled Environment for Finance (CEfF) in the Arden and GEM Commissioning Support Unit

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

4. Arden and GEM Commissioning Support Unit carry out the following processing activities within the CEfF 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/or provider backing flow data.

b. Once the provider backing information is received, this 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. are in relation to a patient registered with a CCG GP or resident within the CCG area.

iii. The health care provided should be paid by the CCG in line with CCG guidance.

5. The CCG are notified that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between Arden and GEM Commissioning Support Unit CEfF team and the provider, meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management reporting detailing the total quantum of invoices received pending, processed etc.

INVOICE VALIDATION - Liaison Financial Services Ltd

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

2.The DSCRO pushes a one-way data flow of SUS+ data into the Controlled Environment for Finance (CEfF) in the Liaison Financial Services Ltd.

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

4.Liaison Financial Services Ltd carry out the following processing activities within the CEfF 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/or provider backing flow data.

b.Once the provider backing information is received, this 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.are in relation to a patient registered with a CCG GP or resident within the CCG area.

iii.The health care provided should be paid by the CCG in line with CCG guidance.

5.The CCG are notified that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between Liaison Financial Services Ltd CEfF team and the provider, meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management reporting detailing the total quantum of invoices received pending, processed etc.

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 patient’s responsible commissioner, but does have a written contract with another NHS commissioner/s.

4. Budget control of the CCG.

INVOICE VALIDATION - Liaison Financial Services

1. Validation of Continuing Healthcare related invoices and payments

2. Independent Identification of potential overpayments made by the CCG through invoice validation

3. Liaising with providers with a view to recouping these monies

4. Review is completed for the retrospective period from date of contract with Liaison Financial Services back to 01/04/2013.

5. Reviews take 3-9 months depending on number of claims to investigate and resolve

6. Liaison Financial Services will repeat the exercise 2-3 years later

7. CCGs are able to request reviews to be done more frequently

8. SUS+ will only be requested each time a review was completed, and maybe requested at different times as independent reviews

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.

INVOICE VALIDATION - Liaison Financial Services

1. Financial validation of activity

2. CCG Budget control

3. Assurances over the robustness of internal control mechanisms relating to the payment of invoices and/or suggested improvements

4. Identification and recovery of monies which would otherwise be lost

5. Meeting commissioning objectives without compromising patient confidentiality

6. The avoidance of misappropriation of public funds to ensure the ongoing delivery of patient care

7. Benefit delivered 3-9 months from receiving data, depending on number of claims to investigate and resolve

Not stated in the register.