Evidence submitted by the Royal College
of Paediatrics and Child Health (EPR 59)
1. The Royal College of Paediatrics and
Child Health would like to make the following submission to the
House of Commons Health Select Committee in response to Health
Committee Press Notice number 12 announcing the enquiry into the
Electronic Patient Record and its use and inviting contributions
of written evidence to the Committee regarding this enquiry. The
main objects of the College are to advance the art and science
of paediatrics, improve standards of medical care to children,
and to educate and examine doctors in paediatrics. Additionally,
the College has a function in providing information to the public
on the health care of children. The following points deal specifically
with the needs of children and young people.
2. There must be adequate safeguards for
confidentiality. This is primarily a technical design issue although
staff training will be required. Where there are genuine safety
concerns, for example in the context of a partner fleeing form
domestic violence, safeguards about revealing the address and
location of the family can be increased without the health data
needing to be hidden.
3. Regardless of the complexity of information
being held on the system, it cannot be in the interests of children
and young people for their data to be withheld from the system.
Indeed if parents are able to prevent their children's data from
being entered onto the system it is likely that the planned information
sharing index supporting the aims of the Government document Every
Child Matters cannot be developed. Most parents can see the benefit
of health information being shared and it is likely that the most
vulnerable children, whose parents desire to disengage from services,
would be the ones asking for their children's data to be withheld.
4. Access to named patient data should be
based on the individual's role and justifiable on the basis of
need to know (for instance in order to deliver health care). There
should be a clear audit trail and regular audits of who has accessed
what data.
5. Basic demographic data (such as name,
date of birth, sex, address, General Practitioner with whom registered
and educational establishment attended) will need to be transferred
form the national spine to set up the information sharing index
(ISA), which will also carry the name of involved professionals
(barring some specified exempt services such as sexual health
services) and whether a common assessment framework has been carried
out. Detailed specifications for the ISA will be available from
the DfES.
6. If we assume that the delivery of care
includes secondary uses of data such as commissioning and auditing
services this should include monitoring of selected outcomes of
key processes such as immunisation coverage, waiting times for
treatment for disabled children and age at identification of severe
hearing loss among many others. The data should be available subject
to confidentiality agreements to agreed research projects. In
some cases it may not be possible to obtain retrospective subject
consent but if no harm is deemed likely (as for testing of anonymised
stored blood samples) the research should still go ahead for the
benefit of the entire population.
7. A comprehensive record available instantly
throughout England is a dream worth working for but is beginning
to look like a mirage with an ever receding completion date. It
may be more realistic and useful to concentrate on developing
an agreed summary electronic health record for children covering
the child health promotion programme, the domains of the common
assessment framework, the individual's current health problems
and medication and then ensuring immediate transmissibility of
such a summary. Further details can be requested as necessary,
for example, it is useful to know a child has had an operation
for squint but not so useful to have a blow by blow account of
the operation.
8. In our view the delays in the delivery
of the system are due to:
poor communication between IT specialists
and clinicians;? disregard for work that may have already
been done in many clinical departments on their information needs;
a failure to grasp the complexity
of the delivery of health care, especially for vulnerable groups
such as children, patients with mental health and learning disability
and where social care and education are intimately involved;
an unrealistic paceclinicians
cannot set aside seven whole days in the next two months (the
current request for clinical involvement for LORENZO) to develop
IT systems in the face of their current workload. Seconding clinicians
to Connecting for Health (CFH) is only partly the answer as the
clinicians still on the ground are reduced in numbers and still
need to become involved;
an unrealistic aimwhereas
transmitting x-rays is relatively simple using informatics transmitting
complex clinical information and clinical judgements is more difficult.
In our view transmitting summaries in an agreed format, developed
nationally for each subspecialty, would ensure the availability
of essential data.
9. Therefore work should concentrate on
developing the summary templates and their messaging as the fist
step for all areas. The only real success story of CFH so far
is PACS; sending x-rays pictures relied upon a summary of the
information in an agreed format (pixels for pictures plus a report)
being messaged instantly across the entire network.
10. The development of the clinical record
for children is seen as a major priority particularly after the
Lamming report. The potential for timely and accurate information
exchange could potentially save lives by alerting professionals
to abnormal or atypical patterns of care access by parents and
deficiencies in care delivery by professionals. There is high
interest amongst paediatricians to develop this quickly and in
a standardised way. However, the commercial interests of developers
have the potential to slow this development unless appropriate
sharing of intellectual property rights with NHS staff is facilitated.
The DH and DFES need to have a close liaison in the development
of a holistic care record that takes advantage of the developments
such as ISA and CAF.
Dr Hilary Cass
Registrar, Royal College of Paediatrics and Child
Health
16 March 2007
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