Sustainability and Transformation Plans (STP) – how might it impact IG?

STP are a new approach to shared health and care planning, launched in December 2015. It is designed to encourage the sustainability and planning of services across locally-defined areas, rather than individual institutions; and over five years, rather than annually.

If you tried to describe NHS England’s Sustainability and Transformation Plans – or STPs – in ten words or less, you might hear:

• place-based planning
• ACOs (accountable care organisations)
• financial balance
• change
• integration and
• FYFV (Five-Year Forward View).

Simon Stevens, chief executive of NHS England, said that STPs are a way of facilitating “big local choices needed to improve health and care across England”. It is hoped that they will encourage local health organisations to work together to make necessary changes and efficiencies.

An STP fund was made available for applications – £2.1bn 2017-18, rising to £3.4bn 2020-21. To access this funding, areas had to produce an STP, which clearly showed how they will pursue:

• improved health and wellbeing;
• transformed quality of care delivery; and
• sustainable finances
• three aims set out by the FYFV.

So what impact might this have on Information Governance (IG)?

1)      It could make IG less onerous

STPs are intended to increase collaboration and integration across health and care organisations in sensibly-agreed areas. This includes sharing resources and spend on things like technology. It will also mean increased communication between agencies. Therefore, one data sharing policy across the STP could mean less duplication and potentially better use of local resources. However, individual organisations will still be responsible for their own organisational assets under the Data Protection Act.

2)      Or, will it make IG compliance worse?

Change always throws up complications. Without a clear strategy, it could leave big question marks over who owns patient data? Who is responsible for compliance? Integration of health and social care data will be vital when looking at the health of a local population with current consent models thrown up in the air again.

3)      Risk stratification – there could be a lot of work involved

Risk stratification is an important element in the management and planning of health and social care services. It helps commissioners to determine who in a population is at high risk of experiencing particular events – such as unplanned hospital admissions. To facilitate the risk stratification process it is necessary for appropriately authorised parties to have access to personal, confidential data (PCD). Up until now, NHS England has obtained temporary agreement (under Section 251 regulations) to wave common law duty of confidence, to allow access to this information for this purpose.

Health care organisations, particularly emerging STPs, who want to use risk stratification data for additional purposes will have to understand how it can do this compliantly and manage permissions across local areas. We’re already working with a number of organisations to develop a data sharing environment that supports additional uses of anonymised risk stratification data.

If you are confused about how STPs might impact on your IG requirements, or need support in developing a long-term compliant approach that can cover entire health economies, then please get in touch with us.