Friday, 21 January 2005
QOF and FOI – how much is enough?
All GP practices are being visited on an annual cycle by teams of managers, practitioners and lay people as part of “QOF” – the quality and outcomes framework of the new GP contract. Earning “QOF Points” means revenue for practices. We support QOF because it contains incentives for practices to work with patient participation groups, for instance on implementing the outcomes of surveys like the Improving Practice Questionnaire. Patient groups in primary care can have a continuing “critical friends” role in auditing the quality of services and the overall patient experience.
The point is that QOF visits generate lots of data. So it’s not surprising that an increasingly heard question is “how much of the data collected on these visits should be disclosed if a request is made, say by a patients group monitoring a service or an individual patient who is thinking of pursuing a complaint?” The Freedom of Information Act went live (after years of delay) on 1st January. This changes the healthcare chemistry radically. Some PCTs have suggested that they will anonymise practice data when responding to FOI requests. That doesn’t sound like a good idea in light of guidance released last week by NatPact, collated from discussions with the Department of Health.
M-A-C’s reading is this: if it is requested, then everything that the PCT has about a practice that was collected by the QOF visiting team has to be disclosed. This underscores the good practice of only recording things that are based on evidence. Only if the data is subject to one of the FOI’s exemptions can it be withheld or anonymised.
This guidance is current, authoritative and coincides with our understanding of how Richard Thomas the Information Commissioner has said he will interpret the Act. Anonymisation without justification could result in a complaint to the Office of the Information Commissioner, which would most probably produce a reprimand for the PCT and a direction from the IC that full disclosure had to be made. That is as it should be if the balance of power is really to shift in healthcare away from the providers and towards the informed users (who pay for it anyway through taxation). Primary care practices, PCTs and patients may not be aware of the implications of this yet. They need to be sooner rather than later.