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NHS 2010 Reform Bill And What It Means For Health Information Governance Scrutiny

NHS 2010 Reform Bill And What It Means For Health Information Governance Scrutiny

There is plenty for those involved in putting version 9 of the NHS Information Governance Toolkit together to consider. Here are my thoughts:

We cannot ignore that the country is about to embark on the most significant health and social care reforms since the inception of the health service. This has huge ramifications from an information governance perspective.

Not least is the proposal for health and social care integration to result in the convergence of health services and local authority services. Consideration is being given across the country to facilitate this new arrangement in the form of a Social Enterprise, a semi-commercial entity (the same consideration is also being given to public health).

Information Governance Toolkit

Presently, the IG Toolkit only provides (on a non-mandated basis) a guidance framework for social care delivery, which, for the above, perhaps needs to become mandated and merged with the existing primary care toolkit standard.

The next question will be who will oversee these new social enterprises from a quality standards and information governance perspective. Is it the Care Quality Commission (CQC)?

The data that will be managed by these new non-public sector organisations, such as adult services, child health, etc., arguably represents some of the most sensitive of all public sector data. Mandating a strong and robust information governance standard going forward is, I feel, one of the most important considerations to be addressed by the reforms.

We also have additional informatics (information sharing) and subsequent information governance challenges arising from the opening up of the healthcare market to “any willing provider”.

NHS Reform Bill 2012 Regulatory Assignment

NHS trusts and their information governance returns are presently used by both Monitor (at least for foundation trusts) and CQC (for all trusts) to measure capability, quality, etc., the assessment of which can result in a trust losing its foundation status or fitness to practice licence.

The current reform proposals suggest Monitor will take on a role in oversight of the commercial “willing providers,” but there is no mention (at least that I have found) of CQC having any role in the fitness to practice licences.

Of course, the key will be whether the IG Toolkit is extended to make provision for returns from “any willing providers” and whether this will be mandated, as it is with public sector trusts.

Last, but not least, GP Consortia, the IG Toolkit will presumably contain a set of requirements (a merger of current PCT and GP requirements) and, again, a mandate for these organisations to comply with.


To conclude, the semi-commercialisation of NHS service provision through social enterprises and any willing provider changes the landscape sufficiently for perhaps the UK to adopt a more robust approach.

It is perhaps (as some have been suggesting for several years), time for something like the US equivalent of the Health Insurance Portability and Accountability Act 1996 (HIPPA) and the subsequent Health Information Technology for Economic and Clinical Health Act 2009 (HITEC).

Especially given that we are likely to see a significant increase in third-party providers, health insurance and private healthcare adoption across the board due to the reforms.

Personally, I think HIPPA and HITEC equivalents in the UK are inevitable. Once the reform bill is passed, these could be next on the agenda. Who knows, we might even see elements of these appear in the version 9 toolkit release.

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