Guidance

Reasonable Adjustment Digital Flag (RADF)

Page Contents

Introduction

What organisations need to do (Phase 1 & 2)

What do I need to do?

Resources and Other Reading

Introduction

Practices are aware of the need to comply with the Reasonable Adjustment Digital Flag (RADF) requirements which are mandated for use in all care settings in England and sit within both the Equality Act 2010 (sections 20,21,& 22) and the NHS Long Term Plan (section 3.32) and which were published in the Health & Social Care Act 2012 (section 250) in September 2023.

Although there is no GMS contractual regulation relating specifically to Reasonable Adjustment Digital Flag (RADF), there is the compliance clause in the GMS regulations which says:

23.1 Compliance with Legislation and Guidance

23.1.1. The Contractor must comply with all relevant legislation and have regard to all relevant guidance issued by NHS England or the Secretary of State or local authorities in respect of the exercise of their functions under the 2006 Act.

NHSE has information on the Reasonable Adjustment Digital Flag (RADF) which says:

What the Reasonable Adjustment Digital Flag is and why this should be implemented

The Reasonable Adjustment Digital Flag is a national record which indicates that reasonable adjustments are required for an individual and optionally includes details of their significant impairments, key adjustments that should be considered and underlying conditions.

NHS England has built the Reasonable Adjustment Digital Flag in the NHS Spine to enable health and care professionals to record, share and view details of reasonable adjustments across the NHS, wherever the person is treated.

The Equality Act (2010) places a legal duty on all health and care services to make changes to their approach or provision to ensure that services are as accessible to people with all disabilities, as they are for everyone else. This duty aims to address the recognition that people with disabilities may appear to have equal access to care and services, but without specific adjustments being made, that access may not be equitable.

In September 2023, a Reasonable Adjustment Digital Flag Information Standard was published (under section 250 of the Health and Social Care Act 2012) that details what all NHS and social care organisations in England are required to do about the flag.

The following information is a high-level summary of actions required and an example of how to achieve compliance.  For more detailed information, please access the Information Standard (and implementation guidance) and the NHS Digital information page.

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What organisations need to do (Phase 1 & 2)

Compliance and implementation of the Reasonable Adjustment Digital Flag Information Standard is by a two-phase approach and organisations should be working towards compliance with phase one by no later than April 2024.

Phase 1: identify, record, flag, share, meet, review reasonable adjustments at local level.

Organisations using their own systems and processes to record reasonable adjustment information locally, i.e. on their own electronic systems and notes ready for sharing via the NHS Spine. Where digital entry is not readily available, organisations should be recording in paper records and subsequently coding digitally either on their own systems or via the National Care Records Service portal.

Phase 2: flag and share reasonable adjustments using the Reasonable Adjustment Flag on the NHS Spine

Phase 1

 Phase 2

Criteria/expectation

Organisations must ensure that processes are in place to identify, record, flag, share, meet and review and update reasonable adjustments on organisation’s own systems/records.

  • Organisations must ensure that they identify and record the disability and associated reasonable adjustment requirement for each of their registered or known patients or service users during routine appointments or interactions with the service.
  • Organisations must ensure that systems are established to place a flag on the records of all people who have any type of disability and are identified as needing reasonable adjustments, using currently available systems and flagging processes, that is highly visible to all those within the organisation who are involved in the care of the patient.
  • The NHS Long Term Plan 2019 says that a ‘digital flag’ in the patient record will ensure staff know a patient has a learning disability or autism. This should be visible to all those who are involved in the care of the patient.
  • Compliance From April 2024 organisations must have a process in place to identify, record and flag reasonable adjustments using currently available local systems.

Criteria/expectation

  • Organisations must ensure their technical operating systems and IT suppliers have engaged with NHS England to commence the technical integration, to and from the Reasonable Adjustment Digital Flag using digital integration.  
  • Suppliers must have signed up to commence technical onboarding (as outlined in the information standard).
  • Compliance By 30 June 2024.
Full conformance

Criteria/expectation

  • Date of full conformance: full implementation of all aspects of the standard is required.
  • Compliance By 31 December 2025.

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What do I need to do?

This section describes in more detail the actions that teams need to undertake in phases one and two in order to achieve compliance by 31 December 2025.

Phase 1

Action 1 required: identify patients with a disability or significant impairment.

Identify people with a disability or impairment as defined under the Equality Act 2010 (a physical or mental impairment that has a substantial and long-term (greater than 12 months) negative effect on ability to do normal daily activities).

How can I do this?

Suggestions on how to achieve this are below (note this is an example and not an exhaustive list):

  • Disability and reasonable adjustment section on all new patient forms/registration documents(eg add a standard line “do you require reasonable adjustments?”).
  • Disability and reasonable adjustment section on recall, review and appointment letters (eg add a standard line “do you require reasonable adjustments?”).
  • Check at first contact.
  • Identification during standard health checks such as annual health checks, long-term condition reviews or during programmes such as immunisations (eg annual influenza campaign).
  • Opportunistically: at any contact with the organisation.
  • Identification through information received in from outside the organisation (such as referral letters, discharge or out-patient letters, community assessments).
  • Review of registers or consideration of cohorts coded with conditions which might result in impairment, such as those with conditions resulting in vision or hearing impairment.
  • Enable and encourage self-identification and optimise awareness (eg posters, practice website information).

Action 2 required: follow 6 steps process to record on local systems.

Organisations using their own systems and processes to record reasonable adjustment information on their own electronic systems and notes, ready for sharing via the NHS Spine in phase 2.

How can I do this?

Suggestions on how to achieve this are below (note this is an example and not an exhaustive list).

Step 1: identify people’s reasonable adjustment needs.

Identify people’s reasonable adjustment needs.

Suggested actions

  • questionnaires
  • easy read questionnaire
  • hospital passports or similar recorded patient needs documents.
  • consultation/ conversations with the person.

Step 2: record

Suggested actions

  • record on digital records systems, consider standardised templates on IT systems.
  • paper form in paper-based systems (but must then be recorded using digital coding to comply with phase 2)
    • record identified needs in SNOMED code if applicable code available.
    • consider ‘bespoke reasonable adjustments code’ if needed (this may include, for example, has hospital passport).

Ideal is no more than 10 specific adjustments per person.

Essential codes (must be added):

  1. impairment with substantial and long-term adverse effect on normal day to day activity (Equality Act (2010) 1326341000000105
  2. requires reasonable adjustment for health and care access (Equality Act 2010) 1108111000000107
  3. consent code:
  • consent given to upload data to Reasonable Adjustment Digital Flag (finding) 1853771000000105 or
  • declined consent to upload data to Reasonable Adjustment Digital Flag (finding) 1853781000000107.

Step 3: flag

Suggested actions

  • obvious and overtly apparent and;
  • highly visible on the cover, title and/or front page of a document, file, or electronic record and/or;
  • highly visible on every page of an electronic record (for example as an alert, flag, or banner)
    • the use of the SNOMED code: “requires reasonable adjustment for health and care access (Equality Act 2010) 1108111000000107”may be used to create local systems for identification of identified reasonable adjustments (a local digital flag).

Step 4: share

Suggested actions

  • add to standard referral letter templates (on IT compliant systems this may be achieved by pulling coded data from patient record)
  • dedicated section on other referral formats (eg forms).

Step 5: meet.

Suggested actions

  • Depending on adjustment needed: eg longer or shorter appointment, information in easy read format.

Step 6: review

Suggested actions

  • Code to be added to indicate reasonable adjustments have been reviewed in suitable timeframe (eg 12 months). Consider adding to standard digital templates.
  1. review of reasonable adjustments needs (procedure); 1833271000000103.

Consent

Consent must be obtained to share on the Reasonable Adjustment Digital Flag on the NHS Spine. Ask in the same way as you normally would when you ask if information can be shared and can be considered as “agreement” to share, eg:

“Are you happy for this to be shared with other organisations in the NHS and social care that will be involved in your care.”

In cases where capacity to make decisions (and therefore to agree or decline to share) is not clearly apparent, a capacity assessment may need to be made and/or a best interests decision made.

 

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Phase 2

Organisations must ensure readiness to share information digitally to and from the digital flag, either via a FIHR® API or via the National Care Records Service.

Organisations must ensure that they and their suppliers have engaged with NHS England by June 2024 to commence the onboarding process for integration and have established a process to upload and download reasonable adjustment information to and from the national Reasonable Adjustment Digital Flag.

More information on these aspects can be found within the information standard documents and the NHS Digital website page.

Summary: checklist of actions

  • Develop a policy which is in line with the Reasonable Adjustment Digital Flag Standard and amend any other impacted policies.
  • Agree a comprehensive approach to identifying disabled people with reasonable adjustment requirements including the new patient process in line with the Reasonable Adjustment Digital Flag Standard.
  • Establish a clear process for recording individuals’ disability and reasonable adjustment information in line with the Reasonable Adjustment Digital Flag Standard.
  • Create and establish a Reasonable Adjustment Flag in local patient record systems, in line with the standard, to highlight and make individuals’ disability and reasonable adjustment information highly visible to staff.
  • Establish a clear process for sharing individual’s disability and reasonable adjustment information in line with the Reasonable Adjustment Digital Flag Standard
  • Establish a clear process for reviewing and updating information on the individual’s records relating to disability and reasonable adjustment information in line with the Reasonable Adjustment Digital Flag Standard
  • Ensure organisational readiness for future digital integrations.
  • Provide training and briefings to staff to explain the Reasonable Adjustment Digital Flag Standard, detail processes to be followed and raise awareness of support which staff can provide themselves. National training for frontline staff via a short e-learning module will be rolled out in April 2024.

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Resources and Other Reading

NHS in conjunction with e-learning for health have an e-learning session on the RADF programme available on the Learning Hub

The GMC guidance Good Medical Practice, which was updated in January 2024, makes several references to making reasonable adjustments in sections 33, 65a and 70e.

The information standard and implementation guidance is available on NHS Digital’s website and a dedicated project mailbox has been set up for all enquiries regarding implementation of this Standard. Contact england.radfproject@nhs.net and include “Reasonable Adjustment Digital Flag” in the subject line.

Further information, including examples of categories and types of adjustments that can be recorded in the Reasonable Adjustment Digital Flag is also available on NHS Digital’s website.

Future NHS has guidance for RADF to support with the implementation phase, as well as a Good Practice Resource Package (if you do not have currently have access, you can request this by clicking on the link and requesting an account).

CQC have information on Meeting the Accessible Information Standard which may also be helpful towards meeting your RADF requirements

Some patients with Learning Disabilities or Autism may already have their Health Passports, detailing their required adjustments, that they can share with you.

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Last Reviewed Date
09/05/2024