DSfC - NHS Mansfield & Ashfield 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 the CCG is 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+) 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.

Invoice Validation will be conducted by NHS Mansfield and Ashfield CCG.

Risk Stratification

Risk stratification is a tool for identifying and predicting which patients are at high risk (of health deterioration and using multiple services) 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 Optum Health Solutions UK Limited , the Nottinghamshire Health Informatics Service (NHIS) (Hosted by NHS Sherwood Forest Hospitals NHS Foundation Trust) and NHS Rushcliffe CCG.

The Nottinghamshire Health Informatics Service is located within Sherwood Forest Hospitals NHS Foundation Trust. IT infrastructure for the NHS Mansfield and Ashfield CCG is provided by NHIS, including the SQL data warehouse and secure data centre in which it resides.

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.

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. The data to be released from NHS Digital will not be national data.

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 only 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

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.

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 NHS Mansfield and Ashfield CCG (including historical activity where the patient was previously registered or resident in another commissioner

For the purpose of Invoice Validation:

• CCG of residence and/or registration.

Invoice Validation - Data Processor - NHS Mansfield and Ashfield CCG

1. Identifiable SUS+ 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+ data into the Controlled Environment for Finance (CEfF) located in NHS Mansfield and Ashfield CCG.

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

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

b. Once the 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. In relation to a patient registered with the CCG GP or resident within the CCG area.

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

4. 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 – Nottinghamshire Health Informatics Service and NHS Rushcliffe CCG

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

2. Data quality management and standardisation of data is completed by Yorkshire DSCRO and the data identifiable at the level of NHS number is transferred securely to Nottinghamshire Health Informatics Service (NHIS), who hold the SUS+ data within the secure Data Centre on N3.

3. Identifiable GP Data is securely sent from the GP system to the CCG.

4. SUS+ data is linked to GP data in the risk stratification tool by the data processor.

5. NHS Rushcliffe CCG host an electronic information portal with secure role-based access control. GPs have access to the data (exclusively through the portal) for patients with whom the GP has a legitimate direct care relationship. The portal shows the individual risk of admission scores, highlighting those patients classed as at risk. The only identifier available to GPs in the Risk Stratification data is the NHS number, and this is only shown for their own patients. Any further identification of the patients will be completed by the GP using their own systems.

Access by NHIS is only for identification and authentication. NHIS host the risk stratification system that holds SUS data and access is limited to those administrative staff with authorised user accounts and only substantive employees of the organisation. Data stored for risk stratification purposes is stored separately from other data and this cannot be linked to other data.

Access by NHS Rushcliffe CCG, who host the secure electronic information portal, is limited to those administrative staff with authorised user accounts used for identification and authentication. Staff within NHIS do not access this data.

6. Once NHIS has completed the processing, the CCGs can access the online system hosted by NHS Rushcliffe CCG via a secure N3 connection to access the data pseudonymised at patient level.

Risk Stratification - Data Processor – Optum Health Solutions

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

2. Data quality management and standardisation of data is completed by Yorkshire DSCRO and the data identifiable at the level of NHS number is transferred securely to Optum Health Solutions, who hold the SUS data within the secure Data Centre on N3.

3. Identifiable GP Data is securely sent from the GP system to Optum Health Solutions.

4. SUS+ data is linked to GP data in the risk stratification tool by the data processor.

5. 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.

6. Optum Health Solutions who hosts the risk stratification system that holds SUS data is limited to those administrative staff with authorised user accounts used for identification and authentication.

7. Once Optum Health Solutions has completed the processing, the CCG can access the online system via a secure N3 connection to access the data pseudonymised at patient level.

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.

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 through more effective commissioning of services.

Invoice Validation

Improved data quality;

Financial assurance and financial savings

Risk Stratification

Identification of patients at higher risk of hospital admission/readmission to prioritise the work of GP Practices and Community Care Teams;

Better understanding of patients needs in order to plan and commission preventative services to support people living longer indepently at home