DSfC - NHS Doncaster CCG - IV & Comm

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+) data, which is received into a secure Controlled Environment for Finance (CEfF). The SUS+ data is identifiable and is only used to confirm the accuracy of backing-data sets and will not be used further.

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

Invoice Validation with be conducted by NHS Doncaster CCG

Commissioning

To use pseudonymised data to provide intelligence to support the commissioning of health services. The data (containing both clinical and financial information) is analysed so that health care provision can be planned to support the needs of the population within the CCG area.

The CCGs commission services from a range of providers covering a wide array of services. Each of the data flow categories requested supports the commissioned activity of one or more providers.

The following pseudonymised datasets are required to provide intelligence to support commissioning of health services:

- Secondary Uses Service (SUS+)

- Local Provider Flows

o Acute

o Ambulance

o Community

o Demand for Service

o Diagnostic Service

o Emergency Care

o Experience, Quality and Outcomes

o Mental Health

o Other Not Elsewhere Classified

o Population Data

o Primary Care Services

o Public Health Screening

- Mental Health Minimum Data Set (MHMDS)

- Mental Health Learning Disability Data Set (MHLDDS)

- Mental Health Services Data Set (MHSDS)

- Maternity Services Data Set (MSDS)

- Improving Access to Psychological Therapy (IAPT)

- Child and Young People Health Service (CYPHS)

- Community Services Data Set (CSDS)

- Diagnostic Imaging Data Set (DIDS)

- National Cancer Waiting Times Monitoring Data Set (CWT)

- Civil Registries Data (CRD) (Births and Deaths)

- National Diabetes Audit (NDA)

- Patient Reported Outcome Measures (PROMs)

- e-Referral Service (eRS)

- Personal Demographics Service (PDS)

- Summary Hospital-level Mortality Indicator (SHMI)

- Medicines Dispensed in Primary Care (NHSBSA Data)

- Adult Social Care Data

Processing of the Medicines Dispensed in Primary Care (NHSBSA Data) dataset is only permitted to provide intelligence about the safety and effectiveness of medicines, as specified by the NHS Business Services Authority (NHSBSA) Medicines Data Directions 2019.

The pseudonymised data is required to for the following purposes:

§ Population health management:

· Understanding the interdependency of care services

· Targeting care more effectively

§ Data Quality and Validation – allowing data quality checks on the submitted data

§ Thoroughly investigating the needs of the population, to ensure the right services are available for individuals when and where they need them

§ Understanding cohort's use of different levels of service

§ Monitoring population health and care interactions to understand where people may slip through the net, or where the provision of care may be being duplicated

§ Modelling activity across all data sets to understand how services interact with each other, and to understand how changes in one service may affect flows through another

§ Service redesign

§ Health Needs Assessment – identification of underlying disease prevalence within the local population

§ Patient stratification and predictive modelling - to identify specific patients at risk of requiring hospital admission and other avoidable factors such as risk of falls, computed using algorithms executed against linked de-identified data, and identification of future service delivery models

§ Demand Management - to improve the care service for patients by predicting the impact on certain care pathways and support the secondary care system in ensuring enough capacity to manage the demand.

§ Support measuring the health, mortality or care needs of the total local population.

§ Provide intelligence about the safety and effectiveness of medicines.

§ Allow analysis of patient pathways across healthcare and social care.

The pseudonymised data is required to ensure that analysis of health care provision can be completed to support the needs of the health profile of the population within the CCG area based on the full analysis of multiple pseudonymised datasets.

Processing for commissioning will be conducted by North of England CSU and Attain Health Management.

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:

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

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 section 3 are listed below. This also includes the purpose on which they would be applied -

For the purpose of Commissioning:

• Patients who are normally registered and/or resident within the NHS Doncaster CCG (including historical activity where the patient was previously registered or resident in another commissioner).

and/or

• Patients treated by a provider where NHS Doncaster CCG is the host/co-ordinating commissioner and/or has the primary responsibility for the provider services in the local health economy – this is only for commissioning and relates to both national and local flows.

and/or

• Activity identified by the provider and recorded as such within national systems (such as SUS+) as for the attention of NHS Doncaster CCG - this is only for commissioning and relates to both national and local flows.

For the purpose of Invoice Validation:

• CCG of residence and/or registration.

Microsoft Limited provide Cloud Services for NHS North of England Commissioning Support Unit 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

Pulsant and IT Professional Services Ltd 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.

Invoice Validation

1. Identifiable SUS+ and PDS Data is obtained 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.

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

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.

Commissioning

The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:

1. SUS+

2. Local Provider Flows (received directly from providers)

a. Acute

b. Ambulance

c. Community

d. Demand for Service

e. Diagnostic Service

f. Emergency Care

g. Experience, Quality and Outcomes

h. Mental Health

i. Other Not Elsewhere Classified

j. Population Data

k. Primary Care Services

l. Public Health Screening

3. Mental Health Minimum Data Set (MHMDS)

4. Mental Health Learning Disability Data Set (MHLDDS)

5. Mental Health Services Data Set (MHSDS)

6. Maternity Services Data Set (MSDS)

7. Improving Access to Psychological Therapy (IAPT)

8. Child and Young People Health Service (CYPHS)

9. Community Services Data Set (CSDS)

10. Diagnostic Imaging Data Set (DIDS)

11. National Cancer Waiting Times Monitoring Data Set (CWT)

12. Civil Registries Data (CRD)

13. National Diabetes Audit (NDA)

14. Patient Reported Outcome Measures (PROMs)

15. e-Referral Service (eRS)

16. Personal Demographics Service (PDS)

17. Summary Hospital-level Mortality Indicator (SHMI)

18. Medicines Dispensed in Primary Care (NHSBSA Data)

19. Adult Social Care Data

Data quality management and pseudonymisation is completed within the DSCRO using University of Nottingham open pseudonymiser tool - a standalone windows desktop application which creates a digest of one or more columns of a CSV file, using a shared key (SALT file) controlled by Yorkshire Data Services for Commissioners Regional Office and is then disseminated as follows:

Data Processor 1 – NHS North of England Commissioning Support Unit

1. Pseudonymised SUS+, Local Provider data, Mental Health data (MHSDS, MHMDS, MHLDDS), Maternity data (MSDS), Improving Access to Psychological Therapies data (IAPT), Child and Young People’s Health data (CYPHS), Community Services Data Set (CSDS), Diagnostic Imaging data (DIDS), National Cancer Waiting Times Monitoring Data Set (CWT), Civil Registries Data (CRD), National Diabetes Audit (NDA), Patient Reported Outcome Measures (PROMs), e-Referral Service (eRS), Personal Demographics Service (PDS), Summary Hospital-level Mortality Indicator (SHMI), Medicines Dispensed in Primary Care (NHSBSA Data) and Adult Social Care only is securely transferred from the DSCRO to NHS North of England Commissioning Support Unit.

2. NHS North of England Commissioning Support Unit add derived fields, link data and provide analysis to:

a. See patient journeys for pathways or service design, re-design and de-commissioning.

b. Check recorded activity against contracts or invoices and facilitate discussions with providers.

c. Undertake population health management

d. Undertake data quality and validation checks

e. Thoroughly investigate the needs of the population

f. Understand cohorts of residents who are at risk

g. Conduct Health Needs Assessments

3. Allowed linkage is between the data sets contained within point 1.

4. NHS North of England Commissioning Support Unit then pass the processed, pseudonymised and linked data to the CCG.

5. Aggregation of required data for CCG management use will be completed by NHS North of England Commissioning Support Unit or the CCG as instructed by the CCG.

6. Patient level data will not be shared outside of the CCG and will only be shared within the CCG on a need to know basis, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared as set out within NHS Digital guidance applicable to each data set.

Data Processor 2 – Attain Health Management Services Ltd

1. Pseudonymised SUS+ and Local Provider data only is securely transferred from the DSCRO to NHS North of England Commissioning Support Unit.

2. NHS North of England Commissioning Support Unit add derived fields, link data and provide analysis

3. Allowed linkage is between the data sets contained within point 1.

4. NHS North of England Commissioning Support Unit then pass the processed, pseudonymised and linked data to Attain Health Management Services Ltd.

5. Attain carry out analysis on behalf of the Commissioners' Working Together programme to help evaluate the impact of the South Yorkshire and Bassetlaw (SY&B) Sustainability and Transformation Plan STP / Accountable Care System. The CCG will only receive data relating to that of the CCG. No other partners within the Commissioners' Working Together programme will receive data.

6. Analytic outputs will provide an aggregated picture of service activity and spend across the health & care system in the context of Doncaster within the STP planning footprint and the Doncaster Place Plan. The specific benefit from this will be derived from informing the development of future models of care centred on how best to deploy the service resources available in the care system to optimise access and the coordination of care for the population

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.

Commissioning

1. Commissioner reporting:

a. Summary by provider view - plan & actuals year to date (YTD).

b. Summary by Patient Outcome Data (POD) view - plan & actuals YTD.

c. Summary by provider view - activity & finance variance by POD.

d. Planned care by provider view - activity & finance plan & actuals YTD.

e. Planned care by POD view - activity plan & actuals YTD.

f. Provider reporting.

g. Statutory returns.

h. Statutory returns - monthly activity return.

i. Statutory returns - quarterly activity return.

j. Delayed discharges.

k. Quality & performance referral to treatment reporting.

2. Readmissions analysis.

3. Production of aggregate reports for CCG Business Intelligence.

4. Production of project / programme level dashboards.

5. Monitoring of acute / community / mental health quality matrix.

6. Clinical coding reviews / audits.

7. Budget reporting down to individual GP Practice level.

8. GP Practice level dashboard reports include high flyers.

9. Comparators of CCG performance with similar CCGs as set out by a specific range of care quality and performance measures detailed activity and cost reports

10. Data Quality and Validation measures allowing data quality checks on the submitted data

11. Contract Management and Modelling

12. Patient Stratification, such as:

o Patients at highest risk of admission

o Most expensive patients (top 15%)

o Frail and elderly

o Patients that are currently in hospital

o Patients with most referrals to secondary care

o Patients with most emergency activity

o Patients with most expensive prescriptions

o Patients recently moving from one care setting to another

i. Discharged from hospital

ii. Discharged from community

13. Validation for payment approval, ability to validate that claims are not being made after an individual has died, like Oxygen services.

14. Validation of programs implemented to improve patient pathway e.g. High users unable to validate if the process to help patients find the best support are working or did the patient die.

15. Clinical - understand reasons why patients are dying, what additional support services can be put in to support.

16. Understanding where patient are dying e.g. are patients dying at hospitals due to hospices closing due to Local authorities withdrawing support, or is there a problem at a particular trust.

17. Removal of patients from Risk Stratification reports.

18. Re births provide a one stop shop of information, Births are recorded in multiple sources covering hospital and home births, a chance to overlook activity.

19. Manage demand, by understanding the quantity of assessments required CCGs are able to improve the care service for patients by predicting the impact on certain care pathways and ensure the secondary care system has enough capacity to manage the demand.

20. Monitor the timing of key actions relating to referral letters. CCG’s are unable to see the contents of the referral letters.

21. Identify low priority procedures which could be directed to community-based alternatives and as such commission these services and deflect referrals for low priority procedures resulting in a reduction in hospital referrals.

22. Allow Commissioners to better protect or improve the public health of the total local patient population

23. Allow Commissioners to plan, evaluate and monitor health and social care policies, services, or interventions for the total local patient population

24. Allow Commissioners to compare their providers (trusts) mortality outcomes to the national baseline.

25. Investigate mortality outcomes for trusts.

26. Identify medication prescribing trends and their effectiveness.

27. Linking prescribing habits to entry points into the health and social care system

28. Identify, quantify and understand cohorts of patient’s high numbers of different medications (polypharmacy)

29. Monitoring, at a population level, particular cohorts of service users and designing analytical models which support more effective interventions in health and adult social care

30. Monitoring service and integrated care outcomes across a pathway or care setting involving adult social care

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.

Commissioning

1. Supporting Quality Innovation Productivity and Prevention (QIPP) to review demand management, integrated care and pathways.

a. Analysis to support full business cases.

b. Develop business models.

c. Monitor In year projects.

2. Supporting Joint Strategic Needs Assessment (JSNA) for specific disease types.

3. Health economic modelling using:

a. Analysis on provider performance against 18 weeks wait targets.

b. Learning from and predicting likely patient pathways for certain conditions, in order to influence early interventions and other treatments for patients.

c. Analysis of outcome measures for differential treatments, accounting for the full patient pathway.

d. Analysis to understand emergency care and linking A&E and Emergency Urgent Care Flows (EUCC).

4. Commissioning cycle support for grouping and re-costing previous activity.

5. Enables monitoring of:

a. CCG outcome indicators.

b. Financial and Non-financial validation of activity.

c. Successful delivery of integrated care within the CCG.

d. Checking frequent or multiple attendances to improve early intervention and avoid admissions.

e. Case management.

f. Care service planning.

g. Commissioning and performance management.

h. List size verification by GP practices.

i. Understanding the care of patients in nursing homes.

6. Feedback to NHS service providers on data quality at an aggregate and individual record level – only on data initially provided by the service providers.

7. 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.

8. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services and early intervention of appropriate care.

9. 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.

10. Potentially reduced premature mortality by more targeted intervention in primary care, which supports the commissioner to meets its requirement to reduce premature mortality in line with the CCG Outcome Framework.

11. Better understanding of the health of and the variations in health outcomes within the population to help understand local population characteristics.

12. Better understanding of contract requirements, contract execution, and required services for management of existing contracts, and to assist with identification and planning of future contracts

13. Insights into patient outcomes, and identification of the possible efficacy of outcomes-based contracting opportunities.

14. Providing greater understanding of the underlying courses and look to commission improved supportive networks, this would be ongoing work which would be continually assessed.

15. Insight to understand the numerous factors that play a role in the outcome for both datasets. The linkage will allow the reporting both prior to, during and after the activity, to provide greater assurance on predictive outcomes and delivery of best practice.

16. Provision of indicators of health problems, and patterns of risk within the commissioning region.

17. Support of benchmarking for evaluating progress in future years.

18. Allow reporting to drive changes and improve the quality of commissioned services and health outcomes for people.

19. Assists commissioners to make better decisions to support patients and drive changes in health care

20. Allows comparisons of providers performance to assist improvement in services – increase the quality

21. Allow analysis of health care provision to be completed to support the needs of the health profile of the population within the CCG area based on the full analysis of multiple pseudonymised datasets.

22. To evaluate the impact of new services and innovations (e.g. if commissioners implement a new service or type of procedure with a provider, they can evaluate whether it improves outcomes for patients compared to the previous one).

23. Monitoring of entire population, as opposed to only those that engage with services

24. Enable Commissioners to be able to see early indications of potential practice resilience issues in that an early warning marker can often be a trend of patients re-registering themselves at a neighbouring practice.

25. Monitor the quality and safety of the delivery of healthcare services.

26. Allow focused commissioning support based on factual data rather than assumed and projected sources

27. Understand admissions linked to overprescribing.

28. Add value to the population health management workstream by adding prescribing data into linked dataset for segmentation and stratification.

29. Developing, through evaluation of person-level data, more effective prevention strategies and interventions across a pathway or care setting involving adult social care

30. Designing and implementing new payment models across health and adult social care

31. Understanding current and future population needs and resource utilisation for local strategic planning and commissioning purposes including for health, social care and public health needs.

The CCG has produced an annual report which details the key developments and achievements within the CCG's remit, of which the processing of NHS Digital data has been used to support. The annual report can be found at:

https://www.doncasterccg.nhs.uk/tag/annual/