Somerset LMC Weekly Update Friday 7th June 2019
Date sent: Friday 7 June 2019
Sent to all Somerset GPs and Practice Managers This and previous updates are available here
- Panoramic View the latest blog from LMC Chairman Dr Nick Bray
- Network News
- BMA Clinical Directors conference on 5 June 2019
- EMIS move to Amazon Web Services (AWS)
- YDH E-mail Security
- Current KO41b return
- Childhood Pre School Boosters
- The Potential of Digital Technologies in Primary Care. Webinar Tuesday 25th June 12.30-1.30
Q: Do the PCN Agreement Schedules need to be submitted to the CCG by 30 June 2019?
A: The BMA have advised that the PCN Schedules do not need to be submitted to the CCG. The only requirement is that each PCN should have their agreement in place and signed before 1 July 2019, and inform the CCG that this has been done. It is entirely up to each PCN how detailed these schedules are, and they can be changed or updated at any time according to the PCN’s requirements.
BMA Clinical Directors conference on 5 June 2019: 2019 Dr Rob Weaver Clinical Director in Mendip and LMC member attended the BMA conference in London yesterday with other Somerset Clinical Directors his full report can be found here.
EMIS move to Amazon Web Services (AWS): The GPC have been informed that EMIS has sent out a communication to practices which they believe is potentially misleading. In relation to the plan to move NHS records to AWS (Amazon Web Services), which the GPC supports, their communication states that practices “may wish to inform your patients”. This is incorrect. It is a requirement under GDPR to be ‘transparent’. Practices must inform their patients of significant changes to the way their data is processed, and failure to do so will almost certainly be a breach of GDPR.
Given the potential sensitivity of moving NHS records to AWS this seems to be counterintuitive when GDPR expects openness, transparency and accountability. BMA guidance on GPs’ responsibilities under GDPR states that: ‘Practices must ensure they continue to provide updated information to patients about new data sharing arrangements’. This involves updating practice privacy notices (PPNs) and where practices have the ability to provide electronic alerts to patients relatively easily then these methods should be used. In practical terms this means that where mobile numbers or email addresses are held the practice should use these to make patients aware that new arrangements for data sharing exist and invite them to read the updated PPN. This is set out in the BMA guidance ‘GPs as data controllers’(see bottom page 6, from ‘Ensuring ongoing transparency – keeping patients updated’ to the top of page 8).
The communication also states “and/or undertake a Data Protection Impact Assessment (DPIA)”, which is also incorrect. A DPIA is not an optional alternative to informing patients, it is a standalone mandatory standalone requirement under GDPR that must be carried out prior to any significant or new processing arrangement. If you don’t do a DPIA you are in breach. However, EMIS have helpfully provided a link to a template DPIA that practices can use. It is acceptable under GDPR to “borrow” or share DPIAs where the changes apply equally to many parties.
YDH E-mail Security: We understand that a few practices have expressed concern about the security of emailing pt info to YDH on a ydh.nhs.uk email address.
Please can we reassure you that ydh.nhs.uk addresses are accredited as being at least as secure as nhs.net email addresses and can be reliably used in place of an nhs.net address where required.
As the final faxes are being switched off in the trust, secure email access is even more important. https://www.somersetlmc.co.uk/emailsecurity2018
Any queries can be sent to firstname.lastname@example.org
Current KO41b return: We are aware that there Practice managers have found the new return particularly onerous to complete and submit this was raised nationally and the advice from the GPC below.
Practices are under no legal obligation to complete and submit the current KO41b return – instead the default obligation is for practices to comply with the 2009 complaints regulations.
NHS Digital asked the Department of Health and Social Care to publish a new legal Direction that would provide the necessary legal obligation to complete the KO41b return – to date, no such legal Direction has been published. Without the new Direction in place NHS Digital/NHS England cannot require practices to complete the current KO41b return – this technically becomes a voluntary collection.
In the absence of the new Direction, it remains a statutory requirement for practices to provide complaints data in accordance with ‘The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009’. The May 2019 publication ‘Primary Care Written Complaints KO41b (GP & Dental) Guidance Notes – GP collection’ confirms this view as it advises that ‘It is a statutory requirement to declare complaints information as detailed in the 2009 complaints regulations.’ These regulations requires practices to operate a complaints procedure and make certain information available. A link to the full regulations is available here – see paragraph 18 ‘Annual reports’.
One way of meeting the obligations of the 2009 regulations is to continue to provide the information requested via the previous KO41b return.
Childhood Pre School Boosters: We have been contacted by a few practices that have only been paid at 70% of their target for preschool boosters for 2018/19 when according to their figures have achieved higher. We have raised this with NHS England who agree that there appears to be a problem, if you are affected they have asked that you first raise a query with PCSE https://pcse.england.nhs.uk/contact-us/ When you are in receipt of your CAS number from PCSE please e mail this with a brief description of the problem to email@example.com. Anna has also submitted a similar enquiry to raise this issue from NHSE.
The Potential of Digital Technologies in Primary Care. Webinar Tuesday 25th June 12.30-1.30: This webinar is open to primary care staff working in Cornwall, Devon, and Somerset. We will give an overview of current technologies including apps, devices, Internet of Things, video calls, robotics, online support, use of pre-recorded video, as well as live webinars etc. In particular we will discuss approaches to using digital that may help primary care staff to reduce workloads. The main presenter will be Professor Ray Jones from the University of Plymouth but we will also have panellists from primary care in the region. This is a live interactive webinar in which you can vote to give your views on the feasibility and acceptability of different technologies in primary care, including (for example) whether webinars themselves might be useful for some groups such as those with diabetes, COPD etc.
Please register for the event at https://attendee.gotowebinar.com/register/708310488266939469.
Crown Medical Centre, Venture Way, Taunton, TA2 8QY
Tel: (01823) 331 428
Fax: (01823) 338 561
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