Good TREs work
Neo Health Hub Limited projects
18 data files in total were disseminated unsafely (information about files used safely is missing for TRE/"system access" projects).
Data modelling and analytics — DARS-NIC-692602-Q6P4F
Type of data: information not disclosed for TRE projects
Opt outs honoured: Anonymised - ICO Code Compliant (Does not include the flow of confidential data)
Legal basis: Health and Social Care Act 2012 s261(2)(a)
Purposes: Yes (Commercial)
Sensitive: Non-Sensitive
When:DSA runs 2024-01-15 — 2024-07-07 2024.07 — 2024.11.
Access method: Ongoing, System Access
(System access exclusively means data was not disseminated, but was accessed under supervision on NHS Digital's systems)
Data-controller type: NEO HEALTH HUB LIMITED
Sublicensing allowed: No
Datasets:
- Medicines dispensed in Primary Care (NHSBSA data)
Objectives:
BACKGROUND:
Neo Health Hub Limited utilizes expert pharmaceutical domain expertise to meet data modelling & analytic needs throughout the healthcare sector, as well as software development to produce tools and reports used by health and social care. Data from NHS England is required to achieve the following fundamental aims:
1. Comprehension and quantification of the prescribing trends across NHS England primary Care.
2. Through robust research, to not only add to the body of healthcare knowledge but reveal key prescribing trends and patterns over time in NHS prescribing activity.
3. Application of data to identify key prescribing improvements in terms of the alignment to national benchmarks and consistency of prescribing.
4. Provide solutions to support commissioning, analytical support, and outcomes analytics for NHS organisations, ranging from NHS England to regional teams.
5. Provide services to commercial organisations within life sciences, social care, charities and healthcare providers who will use the outputs and insights provided by Neo Health Hub Limited to work collaboratively with NHS organisations to promote health and improve well-being of patients, leading to more patient centric services.
The intention of the processing is to:
· Achieve widespread benefits to healthcare, including changes to patient care, reduced cost burden and uptake and monitoring of current health policies.
· Provide analysis to decision making bodies in order to enable them to grant patients access to innovative medicines that potentially reduce cost and activity burden within the national health economies across England.
· Contribution of the already existing knowledge within the medical community to ignite further research into improving patient care.
NeoHealthHub Limited requires access to NHS England data for the purpose of providing services to the NHS, healthcare charity organisations and NeoHealthHub Limited's private organisation clients in the health sector. The data will be used to provide services to the following types of clients only:
NHS Trusts
Integrated Care Systems/Boards (ICSs/ICBs)
Sustainability and Transformation Partnerships (STPs)
Primacy Care Teams (including GPs / Nurses)
Pharmaceutical companies
Medical Device companies
Having spoken to members of the NHS regarding their expected usage, it is anticipated that members of medicines optimisation teams and PCN pharmacists will have primary access to the dashboard who will in turn promote its use to members of prescribing accounts to review information they will find of interest or are required to act upon. Due to the project specific access granted to the pharmaceutical industry and the broad nature of access for the NHS, the expected unique user volumes are 70% NHS and 30% pharmaceutical industry.
Expected User Type Private
Initial Reviews will be undertaken to reach an approval of the client company. Successful access applicants will be companies that are able to demonstrate that they already undertake non promotional activities for the benefit of the NHS.
Post this approval being granted, the user types for the company will be reviewed. These users will be those that can demonstrate a direct relation to those non promotional activities which enabled the companies to be approved initially. We will also reserve the ability for select users that are directly linked to research and development or health economics outcomes research to be granted access for non-promotional purposes. Private company user access will be proactively limited, and this will be documented within the agreements signed by private companies with NeoHealthHub Limited.
Expected User Type NHS
Having spoken to members of the NHS regarding their expected usage, it is anticipated that members of medicines optimisation teams and PCN pharmacists will have primary access to the dashboard who will in turn promote its use to members of prescribing accounts to review information they will find of interest or are required to act upon.
INTERVIEWS
NeoHealthHub Limited has undertaken several interviews with members of the NHS for the purpose of understanding their need for the service NeoHealthHub Limited aim to provide. Further details on perceived benefit on each interview are described in section 5d. Questions on these interviews included -
What therapy areas would be of interest to receive further analysis on ?
How they would use this information?
How the information would be used to benefit the health and social care sector?
How the information would benefit the patients within the health and social care sector?
The interviewees flagged that the best delivery formats for the analysis would be:
A secure web based dashboard for each therapy area
An annual report for each therapy area that showcases headlines of the dashboard
NeoHealthHub Limited agreed with the interviewees that the therapy areas with the broadest potential benefit for the analysis would be:
Asthma and COPD (respiratory)
Diabetes
Heart Failure
Insomnia (with a focus on addictive medicines)
Other areas of note were:
HRT therapy, Opioids, Anti Depressants, Lipid Regulators & General Polypharmacy.
Unlimited access will be granted to any user from the NHS or a registered healthcare charity free of charge.
NeoHealthHub Limited will charge all private sector organisations who request access to the outputs. A sustainable percentage of the profits from these sales will be allocated to further development of the dashboard to provide analysis pertaining to direct requests received from NHS users.
Any private sector access will be limited to those agreeing that any use of the data must be in line with it being used solely for projects that will benefit the health and social care sector and must not be in any way used to promote or market their products. It is expected that the predominant use of the data will be as an added benefit that the pharmaceutical company are investing in to make available.
The following pseudonymised NHS England data is requested:
Medicines dispensed in Primary Care (NHSBSA data) necessary to provide information including what types of medication are being prescribed to patients nationally, as well as their frequency. The data will provide the relevant indicators required to build resources aimed at supporting medicine optimisation.
DATA MINIMISATION:
Data will be limited to the latest available and historic data over a five year period. Access to this fixed data period will be maintained within the SDE throughout the Data Sharing Agreement period. The data will be minimised further for each project of work by focusing on specific medicines within the dataset. Analysis will be minimised within the Secure Data Environment (SDE). The minimisation per use will be reviewed and approved by the Data Controllers Managing Director & Director of Information Technology.
CONTROLLERSHIP
NeoHealthHub Limited is the controller as the organisation responsible for determining the purpose and means of the processing. For each project undertaken, NeoHealthHub will seek external review by a current member of the NHS (NeoHealthHub Limited have several NHS colleagues working with the organisation on a temporary contract basis. NHH Ltd consult this member when there is a new project and whether the project aligns with a wider piece of work . The aim is to make sure there is a legitimate purpose and benefit to access this tool for the NHS) who holds a relevant position (suggested to be a position within medicines optimisation) to ascertain the relevance of the project and the balance of benefit to the health and social care sector, patients and the commercial benefit to the private sector. Any private sector procuring access to the outputs will need to agree that the outputs will not be used for promoting or marketing of their products.
NeoHealthHub Limited is self-funding this work through the company's main core income stream which is subscription fees paid by pharmaceutical and healthcare companies.
LAWFUL BASIS
The lawful basis for processing personal data under the UK GDPR is:
Article 6(1)(f) - processing is necessary for the purposes of the legitimate interests pursued by the controller. NeoHealthHub Limited has determined the processing is necessary for its legitimate interests in being able to provide tools and services that will benefit healthcare organisations. NeoHealthHub Limited will use the data to provide commercial services to healthcare providers to enable improved healthcare delivery through identification of more effective medicines.
The lawful basis for processing special category data under the UK GDPR is:
Article 9(2)(h) - processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3; Personal data referred to in paragraph 1 may be processed for the purposes referred to in point (h) of paragraph 2 when those data are processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies.
This processing is necessary for scientific research purposes in accordance with Article 89(1) UK General Data Protection Regulation and Section 19(4)(b)(ii) UK Data Protection Act 2018, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject, as provided for under this agreement.
Expected Benefits:
The service provision via secure access dashboards and annual headlines reports will be made accessible to personnel with NHS emails, health related charities and approved private health care sector employees. NeoHealthHub intend to generate awareness of the dashboards and annual reports initially to medicines optimisation personnel or individuals with medicines efficiencies as a core principle of their role. Based upon feedback gathered during direct interviews with this group, it is expected that they will be initial users of the dashboards who will then further share awareness towards individuals who can either seek further contextual understanding of the results or directly impact the prescribing habits in prescribing locations. Thus, generating benefits to the patients within those locations. It is agreed that sharing health systems data with the research community can also provide insights into strategies to improve the effectiveness and efficiency of health services and measuring the impact of new health policies and interventions. This will be a key principle behind our sharing of data.
NeoHealthHub will also generate awareness with health-related charities who will be able to showcase headlines to their members on relevant areas. This will increase awareness of prescribing variances within the relevant areas and help further increase research potential. Sharing the information with relevant approved personnel within the private sector will increase the potential for awareness within the NHS as the key directive of providing information to this sector will be for them to promote the findings to key personnel within the NHS.
For each private sector request for access, NeoHealthHub Limited will undertake an internal assessment to confirm whether the commercial benefit accruing to the commercial organisation is proportionate to the benefit to health and social care. NeoHealthHub will also seek external review by a current member of the NHS who holds a relevant position (suggested to be a position within medicines optimisation) to ascertain the relevance of the project and the balance of benefit to the health and social care sector, patients and the commercial benefit to the private sector.
If it is concluded that this is not the case, the project will either be progressed or rejected in its entirety.
How does the dissemination benefit the provision of health care or adult social care or the promotion of health?
The services provided to clients are expected to identify improvement opportunities which healthcare provider clients may then exploit by making improvements to services, systems, processes, resources or infrastructure in order to improve planning, patient safety and medicines efficiencies. It is also expected that patient safety and medicines effectiveness compliant behaviours would be observed, learnt from and purposefully maintained.
The use of the data could:
Advance the understanding of prescribing behaviours that may indicate a reduction in patient safety and how these compare across different geographies
Inform planning health services and programmes, for example to improve equity of access to preferred treatment pathways.
Advance the contextual understanding of NHS national priorities to increase patient safety and effectiveness of prescribing.
Lead to the identification or improvement of treatments to improve health and care outcomes or experience.
Provide a mechanism for checking the quality of care regarding patient safety and effectiveness of prescribing. This could include identifying areas of good practice to learn from, or areas of poorer practice which need to be addressed or prevented from occurring.
Help the system on insight generation bespoke to NHS or Charity patient safety or medicine effectiveness requests where they do not have sufficient capacity.
Advance understanding of the need for, or effectiveness of, preventative health and care measures for particular populations or conditions
NeoHealthHub Limited will commit to reviewing all non-patient level data publications from NHS England for all analysis undertaken to best use all freely accessible data alongside the data being applied for. This will help to provide further context to the headlines of the data being applied for.
A key aspect of the interviews conducted was to ask members of the NHS perceived benefits to patients, NHS, and the private sector. Below is a summary from these interviews (grouped by therapy areas):
ASTHMA AND COPD (RESPIRATORY)
1. SABA Overuse Combined with ICS underuse Patient Prescribing Profiling.
Patients being over or under treated are contributors to medicines waste and treatment inefficiencies. The clinical outcomes of these patients have been shown to be worse than well controlled patients which in turn results in additional admissions to hospital. Having simple access to this information will enable actions to be directed in the most requiring areas. It was suggested during the interviews that understanding what the average make up of those patients is and whether they are under or overusing other respiratory medication will enable a plan of potential action to be formalised. With the analysis of historical success section, the user will be able to see whether the processes they have put in place post changes to patient treatment have been successful. This will enable them to review whether the cost and time investment into projects to achieve these targets was justified.
Patients who receive a review of their therapy based upon the change of practice by the Health & Social Care System would benefit from the prospect of reduced risk of exacerbations, admissions and even death.
2. Triple Therapy Treatment.
Access to this information will enable different levels of the NHS to inform and justify projects of review. These reviews hope to result in better patient adherence and persistence and ultimately increase patient care and outcomes. Outcomes may result in lower levels of escalation of care. Reviews of historical changes will also enable refinement of approaches if unsuccessful or reinforcement of these projects.
Patients who receive a review would reduce the number of inhalers they are managing and look forward to the potential of increased adherence and persistence of their treatment. They would then subsequently benefit from the increased clinical outcomes from this result.
3. Inhaler Therapy Review Analysis.
Analysis of persistence post therapy reviews hopes to enable NHS areas to be better informed as to which reviews have the best persistence. They will be able to review their approaches to other areas regarding the prescribing elements of these reviews. They will also be able to isolate stand out success surgeries, PCNs, Sub ICBs and ICBs where the information regarding the logistical aspect of these reviews might be sharable so these also can be integrated into future projects.
Patients are likely to benefit from the improved approaches from the Health & Social Care System. Patients would have therapy reviews that are better informed and would follow case studies of successful reviews undertaken in the past. This would reduce the potential of patients going through reviews that have a lower chance of a low persistence rate.
The private sector could benefit from being able to understand persistence rates which would improve supply management through demand forecasting.
4. Fulfilment of Generic Inhaler Prescriptions.
Analysis of the number of existing and new patients receiving spacers would enable health care professionals to act upon this understanding and promote their increased or sustained usage in line with their local guidance.
Patients would benefit from the improved approaches from the Health & Social Care System. Patients who havent had access to a spacer historically may gain this access if the local care system changes policy or promotes it more in certain areas that are not compliant to the guidance.
DIABETES ANALYSIS
1. Diabetes Prescribing Patient Profiles
Each NHS locality will be able to understand what the predominant treatment pathway is for diabetes medication and how this has changed over time. Comparison to other localities will also enable a review of their own outputs.
Variation of prescribing across England is something that is consistently reviewed and has been shown historically to promote different health outcomes because of this. Patients that are being treated for Diabetes in one area could be treated differently to another. If a certain area is not following optimal prescribing guidance and changes in guidance are implemented and enforced because of a heightened awareness, then patients will benefit from receiving optimal prescribing above what they are currently receiving. This in turn would promote better health outcomes.
The private sector would be able to promote access to the dashboard to increase conversations in areas that are not following the latest guidance. If their products are on the guidance this would increase the volume of product being used. But this would be in line with what is being requested from the guidance developers.
2. Out of Stock Events
The health & social care system will benefit from being able to identify patient groups that are being adversely affected by diabetic drug out of stocks and to understand what the actual affects to patients prescribing is occurring at these times. Action plans would then be able to be put in place for the management of these patients.
Patients being affected by out of stocks and going under the radar would benefit from the chosen actions decided upon by the NHS locality based upon the findings of the analysis.
Private sector companies would be able to align their actions to assisting with medication supply when other companies products go out of stock. Private sector companies whose own products are going out of stock would be able to be fully aware of the effects that these out of stocks are having on their patients and would hopefully look to plan accordingly.
HEART FAILURE
The health & social care system will benefit from being able to identify patient groups that are being treated in certain ways and review the variance of these between different levels of the NHS and National. Action plans would then be able to be put in place for surgeries or areas that sit outside of what is the best treatment profiles.
Patients who reside in areas that dont follow what is the most favourable treatment profiles could benefit from having their treatment reviewed or new patients entering treatment could benefit from the new approaches.
Private sector companies would be able to promote access to the dashboards which could in turn increase awareness of a variance in heart failure treatment. If the health and social care sector were to decide to act upon this, it could in turn lead to the increased usage of certain products which may or may not be those of the company promoting the dashboards use but would ultimately be aligned to the local guidelines.
INSOMNIA CHRONIC INSOMNIA AND INSOMNIA RELATED TO ADHD AND AUTISM SPECTRUM
Each NHS locality will be able to understand what the predominant treatment pathway is when insomnia products are used, they will be able to see what the current prescribing is that falls outside of what is considered to bring optimal safety and how these trends have changed over time. With this insight they would be able to review whether a change in protocol is required or further enforcement required for what they are already promoting.
patients who have been left on Benzodiazepines and Z-drugs for long periods could benefit from having their therapy reviewed. The Long-term use of benzodiazepines or Z-drugs (usually more than 4 weeks) may be associated with:
Tolerance a higher dose is required to obtain the initial effect.
Dependence the person feels they need the medication to carry out day-to-day activities, and/or withdrawal symptoms occur upon stopping or dose reduction.
Other effects of long-term use of benzodiazepines include:
Cognitive effects, anxiety, agoraphobia, emotional blunting, reduced coping skills, and amnesia.
Reduced social functioning due to effects on memory, reduced ability to remember new people, appointments etc.
Depression, either for the first time, or aggravation of pre-existing depression with possible precipitation of suicidal tendencies.
Patients being optimally reviewed could avoid these side effects.
Private sector companies would be able to promote access to the dashboards which could in turn increase awareness of a variance in Benzodiazepines and Z-drugs usage. If the health and social care sector were to decide to act upon this, it could in turn lead to the increased usage of certain products which may or may not be those of the company promoting the dashboards use but would ultimately be aligned to the local guidelines
How will outputs achieve the stated purposes?
Awareness of prescribing inequalities isolated within specific geographies and subsequently the information to act upon these inequalities, could lead to patients receiving optimised care. In response to this new provision of optimal prescribing, the patient outcomes can be expected to improve based upon the clinical decisions for this optimal care being promoted in the first instance.
Medicine overuse is a key measure for the NHS across areas such as respiratory (salbutamol overdependence). The users of the services provided by processing this data will have improved access to information which would allow the systemic review of policies and procedures which may act to improve indicators relating to such overuse. Patients affected by these policies and procedures would in turn benefit from a more controlled provision of these medicines with a potential review of their dispensed medicines.
Certain medicines should be restricted or strictly monitored in use with children or other patient groups. Indicators relating to such medicines and their use in these populations with allow medical professionals to have an awareness and information to act when required. These actions will derive the benefits implied by these restrictions being implemented based on patient safety. The potential benefits may include reduced admissions related to medicines harm and increased effectiveness or reduced complications related to medicines safety issues.
It is hoped that through publication of insights, the findings of this analysis will add to the body of evidence that is considered by the organisations and individual care practitioners charged with making policy decisions for, or within, the NHS or treatment decisions in relation to specific patients.
The NHS will need to take action based on the information provided to them in order to realise the potential improvement opportunities. For example, members of a medicines optimisation team may review their region in a dashboard and isolate a prescribing profile that they would like to propose a route of change. This proposal could be sent to a health care professional with the ability to access the data themselves. On review by the HCP they could choose to address the prescribing habits in their practice which would ultimately benefit the patients under their care as they would start on or be reviewed to the perceived optimal treatment.
Working with individuals from the NHS, NeoHealthHub have aligned the proposed outputs to therapy areas that have a significant impact on a large number of patients, therefore increasing the opportunity for benefit due to the sheer scale of those being affected. Due to the variation of prescribing habits within these areas and the number of medicines available, this again increases the magnitude of impact. Based upon statistics taken from relevant charities, there are 5.4 million people currently living with Asmtha in the UK, 1.2 million people living with COPD, 4.8million people currently living with Diabetes in the UK, 0.92 million people with Heart Failure and it is thought that a third of people will suffer from Insomnia at some point in there life.
How will it be measured?
A core measurement of benefit will be in reports showing access to the dashboards by NHS personnel, as we are aligned to the fact that sharing health systems data can provide insights into strategies to improve the effectiveness and efficiency of health services, we can state that the more individuals accessing insights directly requested by the NHS will achieve a benefit.
NeoHealthHub Limited will seek to gain structured feedback from NHS users to understand the level of benefit gained from the utilisation of the services provided, should access to the data be granted. This will be undertaken annually via a web based questionnaire that will contain closed score based questions as well as open free text questions.
All of the above indicators shown within the services provided will be reviewed in annual reports to showcase not only the current headlines but also the changes in practice. Although indirectly, measures showing positive changes in practice within regions accessing the dashboard could be assumed to have received a benefit from the dashboard.
When will it be achieved?
It is accepted that changes in policy and then the implementation of these changes will take time post awareness of the insights being gained. However, it is hoped that the resulting patient benefits will be achieved shortly after annual planning cycles are concluded by the personnel accessing the dashboard insights.
Outputs:
The expected outputs of the processing will be:
Monthly updated dashboards accessed by the NHS selected Charities and vetted private sector employees.
Annual therapy area reports showcasing headlines from the dashboards developed
The outputs will not contain NHS England data and will only contain aggregated information with small numbers suppressed as appropriate in line with the relevant disclosure rules for the dataset(s) from which the information was derived.
The outputs will be communicated to relevant recipients through the NeoHealthHub Limited's portal being developed solely for this purpose. Clients to the service will be provided access to a secure online portal containing the dashboards produced by this data processing. Initial outputs are expected to be produced between 1 to 2 months from initial data access. The NeoHealthHub Limited team will update the portal monthly. The first annual therapy area reports are expected to be completed 3 months from initial data access.
Processing:
No data will flow to NHS England for the purposes of this Agreement.
NHS England data will provide the relevant records from the Medicines dispensed in Primary Care (NHSBSA data) datasets to NeoHealthHub Limited via the NHS England Secure Data Environment (SDE). The data will contain no direct identifying data items. The data will be pseudonymised and individuals cannot be reidentified through linkage with other data in the possession of the recipient. There are no further flows of data.
Neo Health Hub Limited will utilise medicines dispensed in primary care data to produce dashboards, reports and studies based on aggregated, suppressed, non-sensitive and non-identifiable data with the aim of answering and supporting the following points:
· Awareness of prescribing inequalities
· Awareness of prescribing efficiencies
· improve patient safety by contributing to safer and more effective prescribing - for example, it can be linked to maternity and child health data to study the effect of medicines given during pregnancy.
· enable research and support clinical trials into the medicines used by patients.
· inform planning and assist in monitoring national priorities like anti-microbial resistance
· improve services by helping to measure the uptake and effectiveness of new medicines
· There will also be a distinct focus on prescribing trends per and post the COVID-19 pandemic.
The data will be stored on servers at NHS England via the SDE. The data will be accessed by authorised personnel via remote access to the Secure Data Environment. Personnel are prohibited from downloading or copying data to local devices. The data will not leave England at any time.
Access is restricted to employees or agents of NeoHealthHub Limited who have authorisation from the Managing Director. All personnel accessing the data have been appropriately trained in data protection and confidentiality.
The data will not be linked with any other data. There will be no requirement and no attempt to reidentify individuals when using the data. Analysts from the NeoHealthHub Limited will process the data for the purposes described above.
NHS Englands Controlled Environment is a data storage and access platform that enables approved users to access de-identified data and analytical tools for approved projects. Users must identify themselves via a multi-factor authentication mechanism and are only able to access the datasets detailed within this agreement. Users can request that aggregated outputs are exported from the system following approval by trained NHSE staff. The access and use of the system is fully auditable, and all users must comply with the use of the data as specified in this agreement.
When processing data for insights and analysis NeoHealthHub Limited will ensure all reports before submission to end user are aggregated and small number double suppressed format in-line with NHS Digital's analysis guide.
As per data sharing agreement, all content will fully comply to Data Sharing Agreement between Neo Health Hub Limited and NHS England.
· Disease burden analysis: Present users with descriptive reports on current disease burden by identifying a cohort of patients and assessing the prescribing resource utilisation to better understand the particular disease type within a primary care setting, and target patient group based on real world data.
· Prescribing trend analysis: Present users with views of prescribing pathways for the treatment of specific therapy areas. This will allow further interrogation into the causes of variant in patient prescribing pathways and subsequent impact on polypharmacy and costs.
· Prescribing burden analysis: present users with views of prescribing volumes per patient · Prescribing and medicines safety issues that have arisen due to the COVID pandemic: Neo Health Hub Limited will produce indicators on changes in prescribing that have resulted from COVID allowing commissioners and healthcare professionals to identify and review any issues.