Medical Records, Online Access and NHS App
Accelerating Patient Access to their GP Held Records
From April 2020 there is a contractual requirement for practices to offer all patients online access to all prospective data on their patient record unless exceptional circumstances apply. (Additionally, patients can also ask for their full retrospective medical record, this will require sensitivity and third-party data checking)
- See Regulation amendment 71ZA & 71ZB.
- Lunch & Learn - Managing Patient Records
There have been a number of dates given for the roll out of this programme only to be suspended.
On 29th November 2022 the BMA reached a negotiated agreement with NHS England and DHSC over halting the mass roll out of the records access programme, for those practices who wish to delay the process, and have published a webpage on the current programme which also includes some useful FAQs (see below) that you may have on the current situation, depending upon what your practice has or has not yet put in place.
BMA FAQs
I have submitted a template letter to my system supplier – what happens now?
Your practice will not see the records programme switched on, regardless of whether you batch coded none, all, or a subset of your patient population.
On your behalf, we will be discussing the next steps with NHSE, system suppliers and others.
I haven't done anything – what happens now?
The inference is that you are happy to proceed with the roll out as planned. We are told your system supplier will be in touch with you to discuss what happens next and when. You can still send in the template letter f you do not want the records programme switched on at this time.
On your behalf, we will be discussing the next steps with NHSE, system suppliers and others.
I have batch coded a certain cohort of vulnerable patients to prevent additional access being provisioned but did not send in a template letter – what happens now?
The inference is that you are happy to proceed with the roll out as planned, with prospective access being granted to those patients who didn't have codes added to prevent access.
We are told your system supplier will be in touch with you to discuss what happens next and when. On your behalf, we will be discussing the next steps with NHSE, system suppliers and others.
I have batch coded all my patients to prevent additional access being provisioned at this time but did not send in a template letter – what happens now?
This question is largely academic as even if the new functionality to provide access were provisioned, no new access could occur due to the presence of batch coding to all your patients.
On your behalf, we will be discussing with NHSE and system suppliers whether an option to restore the medical record to its previous state, through the removal of those batch codes, would be beneficial. This would be on the proviso that the roll out does not proceed and any changes to the medical record had the approval of the data controllers.
A patient has requested access – what should I do?
Patients can still request access to their electronic records, as has been the case for a long time.
Patients should be made aware of the implications of access and GPs should ensure it is appropriate and safe for their patients to have access before it is granted.
Further Guidance
For those practices preparing to proceed, the BMA also have guidance and we would suggest practices might like to use the General Practice Readiness Checklist which is accessible on the FutureNHS platform.
There is a channel on the FutureNHS website dedicated to Accelerating Citizen Access with a wealth of documents and resources that you may find useful.
NHS Digital also have a dedicated webpage with a number of resources including The RCGP GP Online Toolkit .
Accelerated Access to GP held Patient Records A summary for the admin team
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Lisa Harding, Director of Primary Care at Wessex LMCs, talks with Caroline Sims, Information Governance Consultant and Data Protection Officer in the Hampshire & IOW area. Listen to the podcast here |
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Caroline explains:
Further Reading: NHS Digital: https://digital.nhs.uk/services/nhs-app |
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104 & 106 Codes
There has been much confusion about what Snomed CT codes can or should be used and what effect they have on the online access if you do. NHSE&I have produced a handy guide that documents these scenarios and this can be downloaded form the FutureNHS website .
What can you do and what is available?
In preparation, there are a number of resources and options that practices may wish to consider.
BMA
The BMA guidance includes:-
- redaction - how and what to consider
- clinical safety concerns
- the legal background
- summary of options.
- template letter for sending to system suppliers
NHSE & RCGP
- RCGP statement on patients’ access to their GP records
- NHS England wrote to general practice staff to detail the need to prepare for this change and the support available, including an updated RCGP GP Online Services toolkit, videos covering key topics, learning from early adopter sites and communication materials for general practice to use to inform their patients.
- A GP practice readiness checklist has also been produced to help practices ensure they have completed all the necessary actions, such as staff training and reviewing of relevant policies and processes.
FuturesNHS - GP Online Services Channel
There is a wealth of material, including webinar recordings and slides. we recommend signing up to this channel, it is quick and easy and includes a useful discussion forum for any queries you may have. There are also a number of documents and FAQs .
All staff, including locums, should receive the necessary training with regards to checking and entering information into patient records and familiarise themselves with any change in business processes and GP system functionality. Access to training materials and webinar recordings can be found here.
NHS Digital
- Access to patient records through the NHS App - NHS Digital
- See also - Online Access to Medical Records – Safeguarding
We also have a number of webpages that deal with other medical records issues: -
- Medical Records – Alterations
- Medical Records – Adopted Child
- Medical Records – Handling & Retention
- Parental Responsibility , Access to Children’s Medical Records and Parental Disputes
- Recording Safeguarding concerns in patient records
- Transgender Patients & Gender Reassignments
We also have a number of training resources related to these topics. Please refer to Wessex LMCs Education, Training and Development
Clinical System Guides
An EMIS guide for redacting a consultation
A TPP guide for redacting a consultation (Please note that due to the configuration of your system you may not have all 3 processes available to you)
Consider using a test patient in your clinical system and similarly a test patient in the NHS App to see how actions within your clinical system will look to the patient within the App. NHS Digital have full details of how to do this. The NHS App test patient can be set up on a computer or laptop, as well as a smartphone, android or tablet.
With our kind thanks to Dr Michelle Sharma from BSW who has produced 
a crib sheet or all healthcare professionals that shows how to “Redact from online view”.
NHS App Access to GP Health Records - Patient Communications for Practices
NHS Digital have produced some materials you can use to inform patients about having access to their GP health records.
Further Reading
Online Access to Medical Records – Safeguarding
Information Governance Lunch and Learn
Subject Access Requests & Dealing with Third Party Data recording
Data Sharing Update from Caroline Sims at the PM Conference, June 2022
Information Governance with Adam Horton-Tuckett - from PM Webinar 25 May 2022
NHS Acronyms and Abbreviations:
