Is CfH worried about mass opt-outs of summary care records?

NHS Connecting for Health is concerned about possibility that GP practices will use the “93C3” Read codes electronic flag to opt-out their patients in bulk from having medical details uploaded to the BT-run Summary Care Records database, according to GP Neil Bhatia.

He says that CfH is seeking to persuade the Information Commissioner’s Office to issue advice that bulk opt-outs shouldn’t happen or may even be unlawful.

If many GP practices opt out their patients, it would jeopardize the success of the SCR programme, for if doctors repeatedly access the NPfIT SCR database and can’t find medical summaries for their patients, they’re likely to give up trying.

And it’s s easy for GPs to bulk opt out patients – it takes only a few minutes.

Bhatia says that in additionto the 93C3 code, GPs could create a further, custom code labeled “93C3code addedto prevent upload to SCRwithoutexplicit consent”.

Addingboth the custom code and the 93C3 codewould allow anyone who looks at the record, including the patient, tounderstand clearly why the code was added to the record, saysBhatia.

Officials at Connectingfor Health say that the 93C3 code should be put on patient records onlyif patients have specifically opted out of having an SCR.

Butsome GPs say it’swrong to upload the records of patients who have not read theinformation packs, or who haven’t received them because they have movedaddress, or who don’t understand opt-out or opt-in, or who haven’tstated whether they wish to opt in or out, or who don’t understand thatSCRs can be enriched with comprehensive medical information without anyfurther explicit consent.

For CfH, the threat of bulk opt-outs isdeeply worrying. If nothing else, the Read Code 93C3 on a patient’s GPrecordwill stop the upload of Release 2 (non-GP information) to the SCR. It’llalso stop the SCR being “enriched” later with medical informationbeyond allergies and medications. 

Early last month, guidance toGP Practices by Londonwide LMCs was that “for unsure, undecided orundeclared patients, including new registrations or those for whomreturned mail has been received … practices can enter the opt-out Readcode 93C3”.

Most patients will come into the “undeclared”category.

Surrey and Sussex LMCs hassuggested to GP Practices that they can bulk opt-out patients who havenot completed an opt-out form, if they have warned patients that that’swhat they are going to do.

The official BMA advice is thatpractices should not dissent on behalf of their patients unless it isfor data quality reasons – which still leaves the door open to bulkopt-outs, as SCRdata quality is an issue at some GP practices.  


On the wider question of whether there is strong support for theSCR, the answer is that support is mixed.

In secondary carethere is evidence of low use. Researchers at University College London,in their independent evaluation of the SCR scheme, reveal in aconfidential draft report that NHS Connecting for Health has undertakenan internal inquiryinto the relatively low uptake and use of the SCR, particularly insecondary care settings.

That said, CfH says that out-of-hoursdoctors access SCRs hundreds of times a week.


Who’sresponsible for mistakes in summary care records? – IT ProjectsBlog

Confidentialreport on Summary Care Records finds database is inaccurate – ITProjects Blog

Callme paranoid, but why isn’t there more outrage over Google’s spies andan NHS database holding all your secrets? – Daily Mail’s StephenGlover