2. Which clinical records should be included in hospital data submission?

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1 Hospital FAQs Episode record data 1. What is the minimum activity volume required to join PHIN? There is no minimum activity volume in the Competition and Markets Authority (CMA) Order. Any healthcare facility admitting patients for private day case or overnight treatment is required to submit data to the Private Healthcare Information Network (PHIN). 2. Which clinical records should be included in hospital data submission? Only admitted surgical procedures, day case or overnight stay data is required to be submitted to PHIN - outpatient data not required. 3. Who owns the data that PHIN holds? PHIN owns the pseudonymised episode data that it holds in its database. PHIN also owns the intellectual property relating to the phin.org.uk website. PHIN is a licensee of the HES data and the HSCIC is the owner of that data. Hospitals remain the owner of their data in its original form. 4. How will hospitals and consultants view their data prior to publication? PHIN is developing an online secure information portal for hospitals and consultants to access, view and check their data. This will be available one year in advance of the CMA's publication deadline, of April PHIN will not be publishing any information without prior consent. 5. How long do hospitals have to review data before publication? And what is the process for reviewing the data? The full 2016 data will be available for review at the end of March However, PHIN will be providing access to the secure information portal well in advance of this to allow users to become familiar with the system and begin viewing the data that is available. 6. How do hospitals and consultants amend data errors? Any data errors or missing information will need to be amended by the hospital submitting the data. PHIN cannot change the data it holds. After making amendments, hospitals will need to re-submit the data to PHIN. There will be a delay in the revised data appearing in the secure information portal and then on the public website. 7. How will PHIN reflect variation in hospital and consultant patient case-mix?

2 PHIN will work with different specialty groups to design and approve case-mix adjustment methodologies using ICD-10 coding and other factors. Data without ICD-10 will not be case-mix adjusted. 8. How do hospitals check all the data required is being submitted to PHIN? The PHIN minimum dataset and PROMs file specification (along with patient feedback and adverse events - to be confirmed) provide all the information needed to ensure that hospitals are submitting the required data. 9. How do hospitals check all the data submitted to PHIN is being published? Hospitals should sense-check that the data submitted to PHIN matches the data shown in the secure member information portal. 10. Who is responsible for reporting the episode data if a theatre is subcontracted by another healthcare provider? And which hospital will be recorded on the episode? It is the responsibility of the hospital where the procedure took place to report the admissions data. This facility will be recorded on the episode. Coding 11. How does the NHS Number apply to Private or Overseas patients? The instances where it is difficult to determine the NHS Number for a patient are referred to as complex cases by the HSCIC in July A staff guidance leaflet can be found here: How can private hospitals look up NHS numbers? PHIN recognise that few private patients will know or be able to produce their NHS number. There are various ways to look this up, including: a. Use of a N3 smartcard to directly access the NHS spine: b. Set up of a N3 endpoint look-up for batch tracing c. Use of a HSCIC approved Spine Mini Services Providers: d. Use of the look-up service to be offered by Healthcode e. Use of a look-up provided by another service 13. How should overseas patients, without an NHS number, be coded? For overseas patients you will need to provide a unique number such as National ID or Passport number, details are included as part of the minimum dataset. 2

3 14. Can CCSD coded episodes be converted into OPCS4? No, OPCS4 coding is more granular than CCSD, thus must be natively coded. Some hospitals are natively coding procedures in SNOMED-CT, which has the level of granularity that means it can be mapped or simplified to both OPCS and CCSD. 15. Can bespoke coding, such as that used for cosmetic procedures, be converted into OPCS4? No, OPCS4 should be natively coded. However, many hospitals will be natively coding in SNOMED-CT, which is better suited to cosmetic surgery and can be mapped or simplified to both OPCS4 and CCSD. 16. Will the Royal College of Surgeons (England) recommend additional procedure codes suitable for cosmetic surgery? Yes, the RCSEng is working with the HSCIC and PHIN to identify gaps in OPCS4 for cosmetic surgery coding and are submitting suggestions for the next schedule release. In the meantime, PHIN will accept bespoke coding where OPCS is insufficient. 17. How should diagnosis for cosmetic surgery be coded? ICD-10 must be used to code cosmetic surgery admissions in the same way as any other procedures. The specific nuances for cosmetic surgery are still being defined. 18. How should multiple procedures that occurred in one episode be coded? All procedures must be captured and coded in line with the NHS rules on the dominant procedure. There is also a field in the minimum dataset to capture the intended procedure. 19. How should hospitals capture unexpected complications resulting in a different procedure being performed than intended? The intended procedure is captured in a separate field in such scenarios. Performance measures 20. How should hospitals provide non-patient admission data, such as PROMs to PHIN? All non-patient admission data (i.e. PROMs, adverse events and patient feedback) referred to as numerator data, must be sent directly to PHIN. The submission method is still being finalised, but is likely to be via a secure file transfer protocol (sftp). The final method will be advised shortly. 21. How will PHIN link the PROMs data to the episode data? 3 The HOSPITAL PROVIDER SPELL NUMBER or alternatively Admission ID should be provided as part of both the admission data and the PROMs data for a patient episode.

4 22. What is the minimum number of PROMs scores for statistical analysis to be valid? For secondary use, 30. However, most hospitals intend to use private PROMs as a clinical tool for primary use. Therefore there are no absolute minimum numbers. The data will be cut across two dimensions, hospital and consultant practice, so may have statistical significance on the consultant dimension even if not the individual hospital dimension. 23. Are the same PROMs required for both private and NHS patients? PROMs for private patients are more extensive than PROMs for NHS patients. There is no requirement to do additional PROMs for your NHS patients, though PHIN will support hospitals if they choose to do so. There is a need to be NHS comparable for three specific procedures, namely: hip replacement, knee replacement & groin hernia repair. For these, the instrument used must be matched to the NHS, however the implementation and administration need not be. 24. Do the same PREMs apply to private and NHS patients? To date, PHIN have utilised the Friends and Family Test (FFT) and a subset of the NHS Inpatient Survey to maintain comparability. However, PHIN recognises the limitations of this methodology and is working with members to develop an alternative that will meet the granularity required by the Order. 25. Do hospitals need to use PHIN's patient feedback questions? Yes, this enables the patient to compare hospitals and consultants performance across the sector. 26. What do single specialty hospitals do about implementing PROMs measures? If possible, hospitals should start with implementing the recommended PROMs measures that match their highest volume procedures. If the services are very specialised and do not match any of the first wave of measures, hospitals should contact PHIN. 27. Are hospitals consulted on the calculation and display of performance measures? Hospitals are represented at PHIN s Implementation Forum and various expert reference groups will be given the opportunity to input to the calculation and display of the performance measures. 4

5 Governance 28. Who does the Order apply to? Part 4 of the Order, Information, applies to all operators of private healthcare facilities in England, Wales, Northern Ireland or Scotland (Article 1.5, p2 & Article 20.1, p15). This includes NHS hospitals providing privately funded healthcare services, inpatient or day-case, to private patients, be that in a separate unit dedicated to private patients or within a main hospital site, on a dedicated or non-dedicated basis (Article 2.1, p3, for definition of PPU). Also included are cosmetic surgery providers that undertake inpatient or day-case surgical procedures. Some articles of Part 4 also apply to consultants (Article 20.1, p15). 29. When does PHIN membership become mandatory? PHIN is obliged to offer membership to a number of different categories, Private hospital operators (including PPUs), Insurers and representatives of Consultants. The Order came into force on 1 April 2015, however publication of data is not required until April Due to the lead times in ensuring that adequate data is produced, PHIN is offering membership to private hospitals from the 1 April PHIN will be charging subscriptions for all new private hospital members from 1 November Membership of PHIN is not mandatory, however, the supply of the required information is as is the cost per case processing charge. 30. What are the consequences if a private hospital or private patient unit decides not to submit data to PHIN to comply with the CMA Order? If a hospital chooses not to submit private patient activity data to PHIN and comply with the Order, PHIN's understanding is that this can result in legal action from the CMA. There may be three steps to such action: a. Direction to comply b. Court Injunction requiring compliance c. Contempt proceedings PHIN also believes that regulators, such as the CQC, will consider whether a hospital is meeting all of its legal requirements as part of its inspection process. 31. How are hospitals represented in PHIN's governance structures? There are a number of ways that hospital contribute to the work of PHIN. These include a monthly Implementation Forum, which addresses broad issues arising from implementing the CMA s remedies. PHIN also have representation for hospitals on the Board through 5

6 Fiona Booth, the Chief Executive of the Association of Independent Healthcare Organisations (AIHO). 32. Who can join the Association of Independent Healthcare Organisations (AIHO)? AIHO offers membership to independent healthcare providers, cosmetic surgery providers and private patient units (PPUs) who admit patients for private treatment. 33. Will PHIN sell hospital data to third parties? PHIN will not sell hospital or consultant data or use the data for commercial purposes. 34. Are consultants and insurers members of PHIN? If so, will PHIN charge them for the service? Under the Order, PHIN is obliged to offer membership to a number of different categories, Private hospital operators, Insurers and representatives of Consultants. PHIN is not currently charging Insurers or Consultants, as they are not accessing the service. PHIN reserves the right to charge both Consultants and Insurers for services provided in the future. Subscriptions 35. How are subscription fees calculated? PHIN charges a subscription based on the cost of carrying out its business. Each year, once we have agreed the amount of money we will need to spend in that year, this total is allocated against the known volume of cases recorded in the previous year to give a cost per case. For example if PHIN s Budgeted Expenditure is 2,277,000 for a given year and there were 690,000 cases, the cost per case would be 3.30 (2,277,000/690,000). The minimum level of any subscription will be 1,000 per annum. 36. How are subscription fees calculated if a hospital cannot provide a full year of data? PHIN will calculate subscriptions on a pro-rata basis, based on known volumes at the point of joining. PHIN will then review the volumes in year two. 37. When do hospitals start paying subscription fees? While the CMA Order came into force at the beginning of April 2015, PHIN is allowing more than six months for hospitals to engage with PHIN before subscriptions become payable. All hospitals will need to be paying subscriptions by 1 November

7 38. How often will hospitals be billed? Hospitals will be invoiced Quarterly. 39. Do hospitals need to pay for NHS patient episodes reported in HES? Until 31 July 2015 NHS funded patient episodes reported through HES were charged at 50 pence per case. PHIN has removed this charge from the start of PHIN s 2015/16 financial year, 1 August Are Consultants and Insurers charged for PHIN services? Insurers and Consultants will not be charged for PHIN services prior to April This will then be reviewed. Consultants will have a crucial role in helping to validate and improve data quality and that is a contribution in itself. Hospital prices 41. Do hospitals need to publish prices? In 2013 large private hospital groups began publishing their self-pay prices. The CMA noted this during their investigation and therefore didn't make it explicit in the Order that hospitals will need to publish prices, as it was assumed this is standard practice. Website 42. Will data be displayed at group and Trust level or hospital level? The data published on PHIN s website will be at hospital level (and consultant level, where the measure is applicable). 43. How do patients find the PHIN website? Private Medical Insurers will inform new customers of PHIN s website when they take out their cover and will remind existing customers of the website when they renew. Insurers will also direct patients to the website when authorisation for treatment is sought. Additionally, consultants will also direct their patients to PHIN s website to compare performance and prices prior to the commencement of treatment. 7

8 44. Does the PHIN website allow patients to search and enquire about treatment with a specific hospital? No. PHIN s website offers information to patients only, and does not have any booking or enquiry functionality. The website will include profile and contact information for individual hospitals, along with links to their websites. 8 NHS Private Patient Units 45. My hospital has no designated private beds or dedicated unit, are we still subject to the CMA Order? Yes, the CMA Order clearly defines what types of NHS facilities are included: PPU means a private patient unit, which is a facility within a national health service providing inpatient, day-case patient or outpatient privately-funded healthcare services to private patients; such units may be separate units dedicated to private patients or be facilities within a main national health service site which are made available to private patients either on a dedicated or non-dedicated basis. 46. My hospital only carries out very low volumes of private patient activity, are we subject to the Order? Yes. The Order does not stipulate a minimum volume of private patient activity in NHS hospitals. Therefore NHS hospitals providing any volume of admitted private patient procedures are subject to the Order. If a hospital chooses not to submit private patient activity data to PHIN due to low volumes, then they should make sure the Trust s Board are fully aware of this decision, and its implications. From PHIN's understanding, failure to supply the data to PHIN could result in legal action from the CMA. Also note, it is PHIN's belief that the CQC will consider whether a Trust is meeting all of its legal requirements during their inspections. 47. Can private patient episode record data be derived from HES? And if so, can PHIN use retrospective HES data? PHIN have identified several issues with using HES data for our publication purposes. For example, data has been found to be absent and can be difficult to rectify where errors are identified. PHIN's Board has also raised concerns around the granularity and quality of HES data to support a view of performance at consultant level. 48. What will the charges be for the collecting and processing NHS funded patient data? There will be no charge for processing NHS funded activity data. 49. Will PHIN calculate subscription fees based on the volumes reported in HES? No, PHIN will calculate subscription fees for independently funded cases (i.e. non-nhs

9 funded) based on information given in the provider details form, including the previous calendar year s volumes. 50. Do PPUs need a Healthcode contract? No, all data can be submitted independently of Healthcode. 51. Is the PHIN patient consent process different for PPUs? If a PPU believes that its current consent documentation covers submitting data to PHIN, no change may be required. However, it is for hospitals to ensure that their consent processes cover all aspects of the use of the data, including data linkage (for mortalities, transfers and re-admissions). 52. Do NHS hospitals also have to submit all private episode data, as well as NHS data, to the Health and Social Care Information Centre (HSCIC) through SUS/HES? The NHS data dictionary under the Commissioning Data Sets overview (link below) states; The Department of Health requires accurate data for all patients admitted treated as outpatients or treated as an Accident and Emergency Attendance by Health Care Providers, including patients receiving private treatment. The Commissioning Data Sets also includes NHS patients treated electively in the independent sector and overseas. ssioning_data_sets_overview.asp?shownav=1 HSCIC undertake regular checks on the HES dataset and can enforce compliance under the Health and Social Care Act Also, the CQC use the HES dataset, as supplied by HSCIC, to inform their inspections, missing data (and possibly poor data) is something that they would note. Data processor 53. Is there an alternate data processor to Healthcode? Yes, hospitals do not need to use Healthcode, they can submit all their data directly to PHIN via a secure file transfer protocol (sftp) server. 9

10 Consent 54. How should a hospital notify PHIN when a patient does not consent to their information being shared? And what do hospitals do with the episode record? If a patient withholds their consent, hospitals should substitute patient identifiable data elements in the record for an equal value. For example, replacing date of birth with year of birth and Postcode with Postcode sector. Case-mix adjustment for the analysis of the episode itself should still be performed and every episode counted, but not used to produce the linked performance measures, re-admission rates, mortality rates and unplanned transfers. 55. What is the impact on the reported performance measures for a hospital if a significant number of patients withdraw consent? This scenario may result from a lack of communication by said hospital. If a statistically significant portion of data was withheld then this would result in notice to that effect on the website in the sections pertaining to the specifically affected metrics. Consultants 56. What is the communication strategy for informing consultants of the CMA requirements? PHIN will work with hospitals, consultant professional bodies and associations and industry bodies such as the GMC and CMA to raise awareness of the CMA s remedies and their obligations, as well as seeking consultant input into the methodologies for risk adjustment etc. 57. How will PHIN work with hospitals to communicate information to consultants? PHIN will work closely with hospitals, initially through the Implementation Forum to confirm the details of the overall approach, and later with each hospital group to devise a specific plan. Together PHIN and hospitals will: a. Identify and work with early-adopter consultants to give feedback on the performance measure reports produced in the information portal. b. Set a plan for when the consultants at a particular hospital or in a particular specialty should be engaged. c. Support hospital communications through: i. Producing materials to help hospitals to brief their consultants and wider staff ii. Attending regional MAC meetings iii. Producing posters and/ or leaflets for consultants, staff and patients iv. Develop FAQs and other materials to support the handling and resolution of questions and issues 10

11 58. What access will consultants have to their own episode record data before it is published? PHIN is developing an online secure information portal for consultants to view the PHIN data prior to its publication, this will be rolled out to consultants during the first half of No information will be published without prior consent of the consultant. 59. Will PHIN provide consultants with a full view of their practice, including procedures carried out in the NHS and private sector? Yes, consultants will be offered a whole practice view of their data, including work undertaken in the NHS. They will also be able to see a breakdown of which treatments were provided at each hospital they practice at. 60. Which consultant prices must be published? At present, this part of the CMA Order is subject to an appeal, the outcome of which is due in mid As such, PHIN will not be considering fees data until after the decision is reached. 61. Are consultants also members of PHIN? Consultants are data subjects, stakeholders and licensees of the information, but not members. 11