DHSC consultation on the vision for digital, data and technology on heath and care

The Royal College of Physicians welcomes the opportunity to respond to the Department of Health and Social Care's consultation on the NHS’s vision of the future of healthcare.

The RCP supports the aims, guiding principles and priorities of the vision, however maintains that, for there to be real progress that lives up to high expectations, the NHS must fully consider the practical implementation of a digital strategy and the safety of patients and their data.

It is crucial that the NHS takes advantage of the numerous benefits of modern technology to make health and care more integrated, sustainable and person-centred. The outcome of this process must be the NHS developing a more joined-up standard of care, harnessing the ability to generate huge data sets through the use of data analysis to benefit patients, enabling healthcare professionals to better value care, and ensuring that health inequalities are addressed.

The NHS currently has a mixed record with technology, which must be taken into account; implementing the NHS’s vision of the future of healthcare and ensuring interoperability will be challenging. The NHS’s vision of the future of healthcare must be functional and grounded in practicality.

In order for there to be real progress, the RCP believes that:

  • There must be more practical guidance on how this vision will be realised. Questions remain as to how contracting and procurement will be regulated. Systems must be consistent across locations and services in order to have truly integrated care that is accessible to all, both doctors and patients. One suggestion is the identification and promotion of a list of 'essential digital systems', analogous to the WHO list of essential drugs, that all health and care providers are expected to provide for its clinicians.
  • Accompanying this list of essential digital systems could be minimum performance specifications and minimum architectural requirements (eg compliance with PRSB records standards; a fully documented, open API is available for the following functions: all data collected can be extracted into registers for learning health systems and research). These essential requirements should be informed by clinicians and patients about what is important to them.
  • Genuine interoperability must be a priority, including social care and general practice. The standards being developed for semantic interoperability by a collaboration of the Professional Record Standards Body, INTEROPen and NHS Digital are key to enabling systems to share data effectively, and their implementation needs to be promoted. NHS trusts and other NHS entities should be required to purchase systems that have passed semantic interoperability testing. The protection of patients’ data should be carefully balanced with the need to ensure a truly joined-up system; staff from one NHS organisation should be able to access patient information from another in a straightforward way to support care.
  • More evidence and evaluation of health technology is needed. There is an overall lack of peer-reviewed results; we should have the same standard of proof for digital health as we would for any new technology. This will encourage uptake as clinicians and the public can be assured of their quality. We consider that doctors and patients both have a role in assessment of digital technologies.
  • Systems must be straightforward to use with minimal training, and ensure that they deliver immediate user benefits. This will entail going beyond user-centred design and agile development methods to embrace co-production of these tools with typical (ie randomly selected) clinicians and patients, not informatics experts.
  • The current clinical culture needs to change so that everyone who enters data understands that the data they collect is not just for them to use, but will be shared across and beyond their immediate clinical team. High-quality, complete data entry could be incentivised for professionals and patients.
  • It is vital that no patient is left behind if they are unable to engage with new digital health technology. Everyone must have equitable access to high-quality, comprehensive care, regardless of age, socio-economic status and technological literacy.

The RCP looks forward to engaging with this work further in due course. For further information please contact policy@rcplondon.ac.uk.