Plans to allow patients to access any future entries to their patient records via tools such as the NHS app are due to go ahead from 1 November. This deadline has been pushed back twice in order to make changes to the process after concerns were raised by doctors.
However, with just a week to go until the deadline for rolling out access from next month, the RCGP has made clear that practices can consider delaying the move if they believe it cannot go ahead safely.
The BMA, meanwhile, says its GP committee is 'not confident' that all practices can uphold information governance and clinical safety obligations if they roll out access to full electronic records from 1 November - and has urged practices to write to their IT system suppliers to request a delay.
What has the BMA said?
The BMA has issued new guidance to practices this week. It highlights that although the association supports patient access to records, it is concerned that this change comes at a time of unprecendented pressure on practices and that no additional resources have made available to support effective implementation.
The BMA also says it has 'significant clinical safety concerns that the redaction software is not fit for purpose.' At present the software doesn't allow for individual words or phrases to be redacted so it is 'all or nothing'.
This potentially means 'too much material will be hidden from the patient view due to the poor functionality of current software, potentially hiding important clinical information from the patient', the BMA says.
The association has also raised concerns about redactions not remaining in place following a record transfer. Its guidance says: 'The fact that redaction does not remain in place following a GP2GP transfer is particularly worrying, and will also lead to duplicated efforts in reviewing medical records should a patient who had full access request it again after moving practice.'
The guidance suggests that practices who do not feel ready for the change can write to their system supplier requesting that automatic access is not turned on. The BMA says practices are within their rights to do it because they are the data controllers. It has also provided a template letter that they can use to do this (see link below).
The guidance also suggests that practices could:
- Run a focused search and subsequently apply batch exemption coding to those patients identified through the search using SNOMED code 1364731000000104 ('Enhanced review indicated before granting access to own health record').
- Apply batch exemption coding for the full practice list using SNOMED code 1364731000000104 ('Enhanced review indicated before granting access to own health record'). The BMA says this will not revoke access to patients who already have online access but it will prevent any of those patients getting prospective (future) full record access if they do not already have it.
The BMA says delaying record access will 'allow practices to undertake the necessary preparation and training to facilitate a safe implementation of the programme with practices able to work through the GP readiness checklist at a pace that fits with business continuity whilst maintaining delivery of essential services.'
What has the RCGP said?
Meanwhile, the RCGP says: 'The workload and workforce crisis facing general practice severely limits the ability of GPs to engage with any additional programmes of work, with priority rightly given to providing direct care for patients. In addition, while some improvements have been made to redaction functionality, NHS England has not yet delivered on all of the technical solutions the college proposed last year.
'Concerns have also been raised that other parts of the healthcare system are not sufficiently informed about what this means for their communications with general practice and about the implications of automation for the role of GPs as data controllers. The college has communicated these concerns to NHS England on a regular basis, and highlighted NHS England’s responsibility to fully consider the risks associated with this programme and the legal basis under which it is implemented.
'It is appropriate that practices that feel ready to do so proceed with expanding record access, but the college would never encourage practices to go ahead with a course of action that they feel would jeopardise patient safety. Practices must consider the benefits of providing record access against their own level of preparedness and capacity to redact sensitive information safely, and decide whether to delay access in order to prepare further.'
What does NHS England say?
An NHS England spokesperson said: 'Giving patients greater access to their health data gives them the tools they need to better manage their own health and reduces pressure on practices, with patients able to access information such as test results at a touch of a button without having to contact their GP.
'The NHS wrote to general practices in July outlining the actions needed to safeguard their patients during this move, alongside a package of support developed in partnership with the RCGP and patient groups to help them prepare, and this support will continue to be available to all practices.'
- You can find the new BMA guidance and template letter here