The NHS generates a lot of data: for example, data about the number and cost of procedures carried out, waiting times and the numbers and cost of prescriptions. This blog is not about that data, this blog is about governance: the huge number of documents that NHS organisations produce from their meetings.
Every NHS Trust has to hold its board meetings in public and publish its board papers. Under the previous legislation Foundation Trusts could exclude the public from board meetings, but under the Health and Social Care Act 2012 Foundation Trusts must hold board meetings in public and publish board papers. Trusts hold board meetings monthly, every other month or once every three months. (It is bizarre that Hinchingbrooke has just four board meetings a year, with less information made public in each meeting than most trusts provide in their monthly board meetings.) Every year NHS Trusts and Foundation Trusts have to publish an annual report and a quality report. Foundation Trusts also have to publish an annual forward plan outlining their plans for the following three years.
From April 2013 we will see a huge number of new organisations. These include the statutory NHS Commissioning Board (NCB), Clinical Commissioning Group (CCG) boards and local authority Health and Wellbeing Boards (HWB). Further, there will be non-statutory local Healthwatch, NCB regional arms (former SHA clusters), NCB local area teams (made up of former PCT clusters) and Commissioning Support Units (CSU). It is unclear how many of these sub committees and non-statutory organisations will publish their papers.
There are also organisations like Care Quality Commission and Monitor (as well as committees of these organisations like Healthwatch England and the Competition and Cooperation Panel), that are specific to healthcare and organisations like the Office for fair Trading, the Competition Commission and the National Audit Office that periodically perform investigations of the health economy and publish reports. Finally, local authorities also have Oversight and Scrutiny Committees for health, adult social care and children's services. There are many other organisations that affect how NHS and social care services are delivered, but I am sure by now you have got the point that every month there are many hundreds of board papers made public (or should be made public).
So how do you access these papers? The only central repository is Monitor which holds the Annual Reports and Forward Plans for Foundation Trusts only (strictly speaking these reports are laid before Parliament, where they are also available, but Monitor provides the most accessible location). If you want to get access to board papers for NHS and Foundation Trusts you have to hunt around their website for them (the best place is to look under the About Us menu, if the site has one). Local authorities have to publish their own committee papers, but again, there is no standard for how or where on their websites these are published, so you have to hunt around their website to find them. We have yet to see what CCG policies will be about publishing public board papers, but is likely that each CCG will decide where on their own website they publish them in a similar way to Foundation Trusts: again, no standard.
The NCB is open about their own board papers, but appear to accept no responsibility for the organisations that they host, so to find board papers for the regional arms you have to seek out and search their websites, and if you want board papers for local area teams and CSUs you will be very lucky to find anything at all.
This is a mess. It has been a mess for years and it is an insult to democracy that it is difficult for people to access these board papers. It is also an insult to the public that no one has done anything about this issue. Luckily, we have a national Czar called the "National Director for Patients and Information", Tim Kelsey. Unfortunately, giving people access to board papers is nowhere on Tim Kelsey's list of things to do, so it seems I have to do his job for him. The following is a strategy that the NCB should implement.
All board papers must be available from a central website. There should be no exclusions, all NHS providers should provide board papers for this website within a month of the meeting. The NCB should also have a policy about historical documents, I suggest that to be able to make any meaningful comparison between organisations we need five years of information, so the NCB should require that all board papers from 2008 to the present should be available, regardless of whether the organisation have had public board papers during that period. (remember: this is about open data.) Similarly, all commissioners (CCGs, local authorities, former PCTs and SHAs) should provide their public board papers for the site. The website should provide search facilities so that users of the website can perform powerful searches across the documents of all organisations.
The National Czar for open data should insist that the board papers of committees, and organisations hosted by his employer (regional arms, local area teams and CSUs) are made public and are published on the central website. Indeed, any government organisation associated with commissioning or providing NHS and social care should make their board papers available through the central website.
Level Playing Field
In the spirit of open data, the National Czar for open data should also lobby the government to ensure that every provider of NHS and social care must publish board papers relevant to the NHS care they deliver. To prevent a Southern Cross type of scandal affecting NHS patients, the government should ensure that all providers of NHS and social care should publish their complete finance board reports. The reason for this is that in many cases the NHS business of such organisations are often the only profitable part of the company, so publishing finance reports of their NHS business will not give a complete picture about the financial health of the company.
The first two suggestions could be started tomorrow with a deadline to have such a website up and running by the end of the year. There is no reason not to have such a website. Any argument about this being expensive to deliver is specious since the government in the recent SI 257 regulations are mandating such a central website for all the NHS procurement tenders, and this potentially will have far more documents that I am suggesting should be made available about governance. The third suggestion - a real "level playing field" of governance - is more difficult, but I think that anyone who is serious about open data would agree that this suggestion is important.
Over to you, Tim Kelsey.