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 ever seen since the inception of the health service, this in itself has huge ramifications from an information governance perspective.
Not least the proposal for health and social care integration to result in the convergence of health services and local authority services, with consideration being given across the country to facilitated 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 then be who will have oversight responsibility for these new social enterprises from a quality standards and information governance perspective, is it Care Quality Commission (CQC)?
The data that will be managed by this new non-public sector organisations, 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) in the measure of 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 part to play with the fitness to practice licences.
The key of course, will be whether the IG Toolkit is extended to make provision for returns from “any willing providers” and if this will be mandated as it is with public sector trusts.
Finally and not least, GP Consortia, the IG Toolkit is presumably going to contain a set of requirements (a merger of current PCT and GP requirements) and again a mandate for these organisations to comply with?
To end with, the semi-commercialisation of NHS service provision through social enterprises and any willing provider I feel change 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 as a result of the reforms, to see a significant increase in third party providers, health insurance and private healthcare adoption across the board.
Personally, I think HIPPA and HITEC equivalents in the UK are inevitable, and once the reform bill is passed then these will be next on the agenda, who knows we might even see elements of these appear in version 9 to start paving the way.