Paul White considers the impact of the new NHS Information Governance (IG) Toolkit v8 release and the mandate for further development of trusts information governance capability and standards.
The NHS IG Toolkit with version 8 has matured into a well conceived and clear set of standards and guidelines that is without precedence. With the trust board level role of Senior Information Risk Owner’s (SIRO’s) now very well established, additional investment and effort required to achieve the increased levels of compliance mandated within version 8, should now be happening as a matter of urgency.
Early milestones to be met
The first major milestone to be reached in the form of the Baseline and Performance Update submission is set for the 31st October 2010, to meet this deadline, assessment of the toolkit 8 requirements needs to be happening throughout the summer period. This paying due respect to the fact that having identified requirements to be addressed there is only five months remaining in the period up until March 2011, within which to take steps to achieve level 2 compliance across all requirements.
This need for urgency and arguably the justification for the setting of increased targets in version 8, is demonstrated by the results of analysis of previous years IG toolkit returns (version 4 through to version 7) from all acute trusts submitting returns in this period (161 in total).
With the exception of just 13 trusts from this group, all had achieved an “overall” GREEN rating with a score over 70%, which is an achievement; however, this in itself does not tell the full story, if we are to pay due respect to the fact that the Information governance toolkit and requirements are intended to provide the mechanism for continuous improvement, not just a snapshot in time.
In the four years 2006 through to 2010 the overall score average, across all trusts has not changed dramatically as can be seen in the table below, with the average variation in the annual scores achieved being just 2.46%.
Whilst there were significant enhancements in the standards achieved by some individual trusts, with the largest leap between two years by any single organisation being 32%, these are cancelled out across the board by reductions of similar sizes in scores at other trusts.
It has to be acknowledged that in considering past performance, the version 8 release of the toolkit contains quite significant changes, not least in the number of requirements to be met, which for acute trusts falls from 62 requirements in version 7 to 45 requirements in version 8. However it should also be noted that the reduction involves only 3 requirements being removed from the toolkit, the remaining difference is created by the merger of 14 requirements into new standards.
Also, new to version 8 is the additional classification of requirements as “Key”, for which the mapping of these against the version 7 submissions indicates that 97.84% of the key requirements have been met. This however does not take into account the need for these to be re-appraised, especially for those involving the merger and/or change requirements between version 7 and 8. Inevitably the changes will require adjustments and investment to realigning current business practices accordingly.
Evidence based approach
The mandate for attainment of level 2 on all requirements by March 2011 has an additional feature of note, in that the attainment level has to be supported with evidence for how attainment has been achieved.
This signals clear intent on the part of the new coalition government and the Department of Health, to seek further improvement in the handling and management of sensitive information across all departments and sections of the health service. Critically at this economically challenging time, it is a statement to the effect that information governance is not an area within which investment should be cut back or reduced.
With this in mind, the mandate for efficiency savings and better use of resources is a significant consideration, for how any further investment in development of information governance compliance levels is made.
Therefore with the additional challenge set by the economic conditions under which further investment is going to be scrutinised, progress on information governance beyond the present ‘status quo’, will require a greater level of collaboration between the customer and suppliers of technologies and specialist services.
Information governance is the cornerstone of future technology investments. If solutions such as the Electronic Health Record are to deliver on the potentially significant contributions to the future efficiency and resource savings required across the NHS, then patient / public confidence in the NHS’s ability to handle sensitive and private information responsibly, is more than ever a primary information governance deliverable.
The are many aspects of the IG Toolkit requirements that are very well served by technology that is readily available, most if implemented correctly deliver a significant range of benefits as well as very good returns on investment, in relatively short timescales. To date however, the NHS has not mobilised itself to using technology for the delivery of information governance on a wide scale
Information governance is certainly one area where technology can make a significant difference in reducing costs and helping to make the service more efficient.