NHS chief data officers concerned by FDP roll-out

NHS chief data and analytics officers (CDAOs) are worried about the way NHS England is running its controversial Federated Data Platform programme.

In a letter to NHS England’s chief data and analytics officer, Ming Tang, the Chief Data and Analytical Officer Network has highlighted issues with the way the system is being implemented, its running costs and the way NHS England is addressing public concerns around the choice of supplier.

The letter, penned by Marc Farr, chair of the CDAO Network and chief data and analytical officer at Kent Hospitals NHS Foundation Trust, said that while the network’s members recognise the need to federate national NHS data and make it available across the country, they are concerned about the system’s implementation and adoption.

One of the issues highlighted is around the consortium led by US data analytics firm Palantir, which has been chosen to deliver the platform.

Farr said in the letter that while it’s not a case of whether CDAOs had a say in the chosen supplier – although the network members believe it is a missed opportunity “to not have been more involved in the procurement as potential future users” – but rather the choice of supplier and NHS England addressing any public concerns regarding the procurement and contract award.

The Palantir-led consortium was chosen in autumn 2023 to lead the delivery of the platform, in a contract worth up to £360m over five years, with the option to extend taking the value to £480m.

The involvement of Palantir in NHS data projects always attracts controversy from UK civil liberties organisations, such as Privacy International, OpenDemocracy and law firm Foxglove. This is largely because its chairman and co-founder is Peter Thiel, reputed to be a right-wing libertarian and a Donald Trump supporter. 

To alleviate these worries, NHS England wrote into the contract that Palantir is forbidden to use patient data for commercial gain and stipulated that although it will be paid for its services, it will have no right to use patient data except as required by the client.

“Public trust around the use of sensitive data is hard won and easily lost. This relationship of trust with our citizens requires constant and careful attention and we receive regular expressions of interest and concern about health data use, including specifically the extent of our engagement with FDP and its supplier(s),” said Farr’s letter.

“We must take into consideration the development of our local data assets and demonstrate responsiveness to these concerns if we are to safeguard and preserve this trust.”

At the end of 2024, more than 100 NHS organisations had signed up to implement the platform. However, another issue raised in the letter is “programme drift”. While many of the members network have signed up to implement the system, “this does not equate to full endorsement”, Farr said.

He pointed out that the original business need for the FDP was to create a data connection capability, federating data and interoperable standards, however, the current roll-out of the platform “appears to be entirely associated with the adoption of specific tools or modules on a single software platform rather than the integration of data”, leaning more towards imposing specific software solutions on NHS organisations.

We already have tools in use that exceed the capability and application of what the FDP is currently trying to develop or roll out

“This presents an issue for many CDAOs because we already have similar tools in use that presently exceed the capability and application of what the FDP is currently trying to develop or roll out at a system level,” Farr said in the letter.

Integrated care boards across the country have previously made significant investments in local data infrastructure, as directed by NHS England, and the transition to the FDP raises concerns about the risk of losing existing functionality.

Farr added that the platform is also solely focused on NHS data, while at a system level, the health needs of the population are met through both health and non-healthcare related services.

“A nationally commissioned platform (FDP) will not be able to meet all the bespoke requirements of a local system to support the health of its citizens through better data and intelligence,” Farr said, adding that this is best done through a locally designed and managed infrastructure.

“CDAOs and other partners across the system are in discussion with a range of government departments about how best to integrate wider public service data at a system level,” the letter stated.

Local NHS organisations are also strapped for cash with budgets dwindling, and the CDAO Network is concerned that there is no independent evaluation of the cost benefits of adopting the FDP.

“The adoption and ongoing maintenance costs as part of a total cost of ownership that will sit with those who choose to use FDP needs to be made very clear before they can commit – especially with many systems under significant financial stress,” Farr said in the letter.

Commenting on the letter, an NHS spokesperson said:

"The FDP is a central pillar of the new operating model and is already delivering for the NHS, helping join-up patient care, increase hospital productivity and ensure thousands of additional patients can be treated each month.

 "The NHS is pleased to note the support of the Chief Data and Analytical Officer’s Network in their letter, and as we roll out the FDP, we are committed to continuing to listen to our stakeholders and frontline staff." 

NHS England is not mandating use of the FDP – at least not yet. However, it has paid for licences for all NHS organisations to use it over the next seven years, and has asked each organisation to provide plans for how they will maximise its use within two years.

Back in 2022, the National Data Guardian warned NHS England that it needed to listen to NHS professionals and the public, and adapt its plans for the platform based on feedback given to avoid another Care.data scandal.

The CDAO Network has asked NHS England for further opportunities for technical discussions around aligning with local needs, and has set out a series of questions for the organisation to alleviate uncertainty around costs and benefits, the use of existing tools, integration and transparency.