There may be times where one healthcare organisation will need to invoice another for treatment given to a patient. This can occur, for example, when you need hospital treatment while away from home on holiday. The hospital at which you were seen may need to invoice us for the treatment you received.
Before paying the invoice, we will need to be sure that we are responsible for your treatment costs and not another CCG, as well as checking to ensure that the amount you are being billed for is correct. This process is known as invoice validation. For invoice validation to occur, a limited amount of information about you needs to be shared between us and the hospital where you received treatment. The following table outlines type of information we may share and justification for use of this information.
North West Surrey CCG uses the services of a health partner, NHS North East London Commissioning Support Unit (NELCSU) to process this data on our behalf to enable the appropriate payment to be processed. NELCSU does not use any information from NHS Digital for this process, the information is provided directly from where you received the treatment. Once the invoice has been paid, the limited information about you is deleted, as it is no longer required. If the information is needed again, to respond to a question, it will be requested, the question answered and the information deleted again.
|Invoice Number||Not PCD||Identifies the relevant invoice and allows associated with backing data||To enable backing data to be matched with the relevant invoice|
|NHS Number||NHS Number||The unique identifier for the patient||Needed to determine if the individual is the responsibility of the CCG|
|Hospital Provider Spell Number/AE or OP Attendance identifier unique within Provider for the patient event||To ensure the same episode of care isn't paid for by the commissioner more than once. For example, a patient may have several attendances of treatment on the same day.||To distinguish between multiple events carried out for a particular patient on the same day.|
Local Patient Identifier, GP
|To ensure any issue or payment is attributed to the same patient||To identify the individual to the healthcare provider. Particularly as NHS Number is not always known by the provider.|
Handling Continuing Healthcare (CHC) Applications
If you make an application for Continuing Healthcare (CHC) funding, Surrey Downs CCG will use the information you provide and where needed request further information from care providers to identify eligibility for funding. If agreed, arrangements will be put in place to arrange and pay for the agreed funding packages with appointed care providers. This process is nationally defined and we follow a standard process and Surrey Downs CCG - use standard information collection tools to decide whether someone is eligible.
Handling Individual Funding Requests (IFR) Applications
If you make an Individual Funding Request (IFR) to fund specialist drugs or rare treatments, Surrey Downs CCG will use the information you provide and where needed request further information from care providers to identify eligibility for funding. If agreed, arrangements will be put in place to arrange and pay for the agreed funding packages with appointed care providers.
Supporting Medicines Management
CCGs support local GP practices with prescribing queries which generally don’t require identifiable information.
Where specialist support is required, e.g., to order a drug that comes in solid form in gas or liquid the medicines management team will order this on behalf of a GP to support your care.
Advice and guidance is provided to care providers to ensure that adult and children's safeguarding matters are managed appropriately. Access to identifiable information will be shared in some limited circumstances where it's legally required for the safety of the individuals concerned.
A Quality Alert is a systemic issue, generally affecting a service, or the ability to deliver a high quality service. North West Surrey CCG's Governance and Quality Teams triage quality alerts (QA's) reverse quality alerts and incidents reported by GPs/Provider organisations. The CCG has a statutory duty to support NHSE with the continuous quality improvement of primary medical services as set out in the HSCA 2012 and the Primary Medical Services assurance framework. For the CCG to triage quality alerts and incidents reported by North West Surrey CCG GPs and providers, the Governance and Quality teams at the CCG may require the relevant individual's NHS number in order to investigate the quality alert or incident.
Post Infection Reviews
Clinical Commissioning Groups collaborate closely with the organisations involved in providing patient care, to jointly identify and agree the possible causes of, or factors that contributed to a patient's infection.
CCGs will lead the Post Infection Review in the circumstances set out in the Post Infection Review Guidance, issued by NHS England. They will be able to use the results of the Post Infection Review to inform the mandatory healthcare associated infections reporting system.
Serious Incident Management
North West Surrey CCG is accountable for effective governance and learning following all Serious Incidents (SIs) and work closely with all provider organisations as well as commissioning staff members to ensure all SIs are reported and managed appropriately. The Francis Report (February 2013) emphasised that commissioners, as well as providers had a responsibility for ensuring the quality of health services provided.
In order for North West Surrey CCG to perform its commissioning functions, information (mostly anonymised) is shared from various organisations which include: General practices, acute and mental health hospitals, other CCGs, community services, walk-in centres, nursing homes, directly from service users and many others.
Your GP uses your data to provide the best care they can for you. As part of this process, your GP will use your personal and health data to undertake risk stratification, also known as case finding.
Risk stratification involves applying computer based algorithms, or calculations, to identify those patients registered with the GP Surgery who are most at risk from certain medical conditions and who will benefit from clinical care to help prevent or better treat their condition.
To identify those patients individually from the patient community registered with your GP would be a lengthy and time-consuming process, which would by its nature potentially not identify individuals quickly and increase the time to improve care.
Your GP Surgery uses the services of a health partner, NHS North East London Commissioning Support Unit (NELCSU) to identify those most in need of preventative or improved care. This contract is arranged by us.
Neither we nor NHS NELCSU will at any time have access to your personal or confidential data. They act on behalf of your GP to organise this service with appropriate contractual and security measures only.
NELCSU will automatically process your personal and confidential data without any staff being able to view the data. Typically they will process your data using indicators such as your age, gender, NHS number and codes for your medical health to identify those who will benefit from clinical intervention.
Processing takes place automatically and without human or manual handling. Data is extracted from your GP computer system, automatically processed, and only your GP is able to view the outcome, matching results against patients on their system.
We have implemented strict security controls to protect your confidentiality and recommend this as a secure and beneficial service to you. At all times, your GP remains accountable for how your data is processed. However, if you wish, you can ask your GP for your data not to be processed for this purpose and your GP will mark your record as not to be extracted so it is not sent to NELCSU for risk stratification purposes.
The lawful basis to use this information for risk stratification has been allowed by s251 NHS Act 2006 and is processed by NELCSU or other approved providers only. For further information on Risk Stratification, please visit https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification/ and http://www.hra.nhs.uk/about-the-hra/our-committees/section-251/
Each NHS organisation and General Practice is required by mandate to have a Caldicott Guardian who has responsibility for satisfying the highest practical standards for handling patient identifiable, confidential and sensitive information. The Caldicott Guardian also actively supports work to enable information sharing where it is appropriate and advises on options for lawful and ethical processing of patient information.
How you can access your records
The Data Protection Act 1998 gives you a right to access the information we hold about you on our records. Requests must be made in writing to:
Head of Corporate Services and Risk
North West Surrey Clinical Commissioning group
58 Church Street
You can email: firstname.lastname@example.org.
We will reply to your request within 40 days from receipt and in order to provide the correct information we will need:
•Your personal details including your full name, address, date of birth, and NHS number so that your identity can be verified and your records located
•A cheque for an initial £10 (rising to a maximum of £50 for health records) made payable to NHS North West Surrey Clinical Commissioning Group
•An indication of what information you are requesting to enable the CCG to locate this in an efficient manner
For independent advice about data protection, privacy and data-sharing issues, you
can contact the;
The Information Commissioner
Phone: 08456 30 60 60 or 01625 54 57 45
Managing conflicts of interest
We manage conflicts of interest as part of our day-to-day activities. Effective handling of conflicts of interest is crucial to give confidence to patients, tax payers, healthcare providers and parliament that CCG commissioning decisions are robust, fair, transparent and offer value for money. It is essential in order to protect healthcare professionals and maintain public trust in the NHS. Failure to manage conflicts of interest could lead to legal challenge and even criminal action in the event of fraud, bribery and corruption.
Section 14O of the National Health Service Act 2006 (as amended by the Health and Social Care Act 2012) ("the Act") sets out the minimum requirements of what both NHS England and CCGs must do in terms of managing conflicts of interest.
Any persons who are included in the declaration of interest registers can contact the Data Protection Officer at; North West Surrey CCG 58, Church Street, Weybridge, Surrey KT13 8DP or e-mail email@example.com.
Patient right to object to processing/opt-out
There are choices you can make about how your information is used, and you can choose to opt out of your information being shared or used for any purpose beyond providing your care.
If you do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please inform your GP practice and they will mark your choice in your medical record.
There are two types of opt-out. You can withdraw either opt-out at any time by informing your GP practice.
Type 1 opt-outs
If you do not want information that identifies you to be shared outside your GP practice, for purposes beyond your direct care, you can register a type 1 opt-out with your GP practice. This prevents your personal confidential information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease.
Type 2 opt-outs
The HSCIC collects information from a range of places where people receive care, such as hospitals and community services. If you do not want your personal confidential information to be shared outside of the HSCIC, for purposes other than for your direct care, you can register a type 2 opt-out with your GP practice.
A direction from Secretary of State sets out the Department of Health policy as to how type 2 opt-outs must be applied and instructs NHS Digital (HSCIC) to apply type 2 opt-outs from 29 April 2016.
When we have collected information about your type 2 opt-out from your GP practice we use that to create a record of all current type 2 opt-outs. We then use that record to check against any set of data that is to be made available by NHS Digital (HSCIC) to another organisation and remove all of your personal confidential information if it is in that data set, before that data are made available.
The direction sets out the scope of when your type 2 opt-out does not apply, such as when there is a legal requirement to release information, or where you have given your consent to a specific release of your information.
There are also some limited circumstances, which are set out in the direction, when we don't apply your type 2 opt-out to information made available. These are cases where:
• The Secretary of State for health has identified the information flow is very important.
• There are complex technical barriers that make it very difficult to apply opt-outs.
For more information on how we collect and use opt-out information see Applying Type 2 Opt Outs
For more information about care records and how to access them see NHS Choices. For details about how public bodies must make information available, see the model publication scheme published by the Information Commissioner's Office.
How long we will keep your information and how we will destroy information
There are different retention schedules for different types of information and types of record. In the NHS, all commissioners and providers apply retention schedules in accordance with the Information Governance Alliance's Records Management Code of Practice for Health and Social Care. For more information, you can access the document here: http://systems.digital.nhs.uk/infogov/iga/rmcop16718.pdf
NHS data are subject to legal retention periods and should not be destroyed unless specific instructions to do so has been determined and received from the Data Controller. Where data has been identified for disposal:
- NHS organisations have the responsibility to ensure that NHS information held in manual form (regardless of whether originally or printed from the IT systems) is destroyed using a cross cut shredder or subcontracted to a reputable confidential waste company that complies with European Standard EN15713.
- NHS organisations also ensure that electronic storage media used to hold or process NHS Information is destroyed or overwritten to current CESG standards as defined at www.cesg.gov.uk. NHS ICT Teams usually carry out or contract out to an approved company to ensure the secure destruction or permanently removal of information from ICT equipment which are NHS assets. In the event of any bad or unusable sectors that cannot be overwritten, the NHS ICT Team or approved contractor shall ensure complete and irretrievable destruction of the media itself.
- It is the responsibility of NHS organisations to retain copies of all relevant overwriting verification reports and/or certificates of secure destruction of NHS information at the conclusion of the contract.
Any arrangement made by NHS organisations to sub-contract secure disposal services from another provider, must comply with clause GC 12 of the NHS Standard Contract and with assurance that the sub-contractor's organisational and technical security measures comply with the 7th Data Protection Act 1998 principle
Your care provider and CCG will endeavour at all times to comply with the statutory duties, laws and NHS policy which govern their use of personal and confidential information. These include the following: