NHS Appraisal. The Pen and Paper Solution

The NHS Appraisal Fiasco is being covered by Pulse. Following the recent security blip covered by the Register, the Department of Health has apparently been writing placatory letters to the local PCTs.

"The Department of Health has written to PCTs stating doctors should not be ‘penalised’ because they are unable to complete their appraisals, after the NHS Appraisal Toolkit was taken offline because of its vulnerability to hackers"

I thought the whole idea of appraisals and revalidation was to prevent the next Dr Shipman. It is clear by the above statement that the Department of Health does not believe that patient safety would be put at risk by the delays caused by their incompetence.

"The move - made in agreement with the BMA and RCGP – has led to huge upheaval in the appraisal system at its busiest time of the year, and could delay the passage to revalidation for those taking part in pilots of the system"

Does this mean, the Department of Health agrees that there should be delays in spotting the next Dr Harold Shipman?! Surely not! All that pomp and circumstance about harassing doctors and punishing them with the sole aim in deviating the pointed finger from the real people responsible for Harold Shipman.

Dr Charles West, a GP Appraiser in Shropshire and parliamentary candidate for the Liberal Democrats, condemned the decision to take the site offline.

‘Technical staff running the system say knowing the potential problem would have allowed them to monitor it for any incorrect use. But the health minister decided the service should be shut down without notice.’

For a target driven National Health Service, it is rather amusing that the Department of Health cannot meet its own targets to prevent the next Dr Harold Shipman. This of course leads us to question whether the Department of Health is really convinced that appraisals and revalidation is the way forward to catch the next serial killer. If they were convinced, they would have made a damn sure that the system was hacker proof before implementing it thereby preventing delays.

There is of course a different solution, the Department of Health could supply all doctors with free pens, a Department of Health Serial Killer Prevention Folder and some NHS Headed paper, envelope and free postage. It may well be more reliable :).

Sadly, it is clear as the light of day that the Department of Health's Microsoft driven system is not hacker proof and never will be. Microsoft's record has not been wonderful.

Of course, there are people like Gary McKinnon who would probably be able to hack past anything the Department of Health creates. It is good to know that doctors' professional assessments can be accessed by any reasonable hacker anywhere in the world. This will no doubt warm the cockles of every doctor who is sitting there with their vast array of appraisals completed by their medical friends.

Of course, again vast numbers of doctors continue to be asleep. Must be all those late night oncalls and low pay in the NHS because few fail to understand what this admission of a potential security breach means. This is of course just another day in the NHSHIT system.

Centralised data = Access by Hackers = No System is Secure.

Read more coverage by the Register here.

NHS Appraisal. No Maximum Security

DOH - No guarantee of Maximum Security

Of late, I have been discussing the various databases that have been created by the National Health Service for appraisals and revalidation. The main discussion has been about the collection of data. Centralized data collection always has serious problems. The Register today reports the predictable problems that are due to be seen in all other medical databases.

"The UK's Department of Health has taken the highly unusual step of suddenly taking a doctors' appraisal website offline for three weeks over concerns it was vulnerable to hacking attacks.

The NHS Appraisal Toolkit was taken down on Tuesday (9 February) and is not expected to return until 3 March.

The site provides an online database that allowed NHS doctors to prepare for their annual appraisals. The database therefore contains confidential information about all GPs' performance, along with a large amount of named patient data including near diagnosis misses, critical incidents and the like.

www.appraisals.nhs.uk was pulled offline without warning to the 27,000 doctors who use it after a security audit sparked fears that the site was insecure, an NHS statement explains. It stresses that the site takedown is a precautionary move and that no attack has actually taken place"

A Reg reader and doctor who first told us of the site downtime explained that the site was used by almost all GPs and many hospital doctors, adding that the takedown could hardly have happened at a worse time. "This at a a time when a huge chunk of GPs in particular are due their annual appraisals," he said.

And that is of course the stupidity of doctors in the United Kingdom. Instead of asking the question " What data is the Department of Health collecting and what will it be used for", they quietly just insert said data and progress forward until disaster strikes".

Many will recall that this was the problem with the MMC/MTAS issue. There was a security breach. Robert Goss tells us about the flaws of the system here.

On the flip side of the coin, it is interesting that the GMC reports a hike in complaints against General Practitioners. Those who know the GMC's database well will know all about Siebel and how even the most vexatious complaints are recorded on their databases to create a " fitness to practise history" of the doctor.

A GMC trial of revalidation has has found clear concerns with the system

"A GMC trial of revalidation has identified ‘clear concerns’ with the system, which doctors are believed to have found excessively bureaucratic and time-consuming, Pulse can reveal"

We should all remind ourselves that appraisal and revalidation were only created because the General Medical Council was incapable of stopping Shipman. No one thought about actually appraising or revalidating the General Medical Council itself. I suppose that would be such a simple solution. Too simple and cost effective for the establishment's liking I suspect. It will be fun to watch the revalidation meltdown while the doctors caught in the middle will run around like headless chickens. That is exactly what happens when the vast majority follow like large sheep in a field. This is called a complete lack of independent thought and misguided faith in a failing system.

Where there is smoke, there's fire

Revalidation.
The Data to Set Your Career on Fire

Following on from my piece on revalidation and databases, I wanted to provide extracts from documentation within the various authorities. This establishes a slipshod approach where the National Health Service has unilaterally decided to collect Fitness to Practise data without any consultation with the medical profession itself. This was a unilateral decision made following the Shipman Inquiry and other inquiries that followed.

First, I present, Mr Finlay Scott's statement to the Shipman Inquiry where he clarified the impact of running roughshod across a doctors livelihood. The data though is retained.

In Paragraph 73 of his statement to the Inquiry, Mr Scott said [ Statement available on the Shipman Inquiry website]

“The disclosure by the GMC to third parties of information about doctors whose fitness to practise is being investigated was a source of some difficulty until 2000, when matters were put on a statutory footing at the GMC’s request. On the one hand, the GMC recognised that its duty to protect patients required, in certain circumstances, the disclosure of information about a GMC investigation to those responsible locally for the doctor. On the other hand, the GMC was very aware of the damage that could be caused to a doctor’s reputation, career and livelihood through disclosure of information about allegations that had not been substantiated and might in due course prove to be unfounded. That this was an uncertain and complex area of law increased the difficulties we faced in making judgments about disclosure in individual cases."

From the General Medical Council by email to me [ please note that Jackie Smith of the GMC denied the existence of such a database in her statement in R v GMC Ex Parte Pal but I decided to show her a email she had written to me some time ago admitting the database issue herself].

“You asked us about our retention of your personal data. The GMC is required to keep records in order to perform its regulatory duties. We currently retain fitness to practise records, details of all complaints and enquiries received about doctors, on a permanent basis. This provides us with a longitudinal view of a doctor's involvement with the GMC. Maintaining Fitness to Practise records on a long-term basis ensures that we have a detailed picture of a doctor’s registration history, which is essential to appropriately protect the public.” Ms Smith went on to say, “Principle five of the Data Protection Act 1998 (DPA) requires data controllers to keep personal data for as long as necessary to perform their specified purposes. We hold records for as long as necessary to perform our statutory functions, balancing the privacy requirements of individual doctors and the public protection needs of the wider community. We are therefore unable to cease processing your personal data in this instance.”

Finally, paragraph 33 of the Kerr / Haslam Inquiry found:

“Regulatory bodies (with responsibility for the regulation and discipline of psychiatrists and other mental healthcare professionals) and the Department of Health should be under a clear duty, in the public interest, to share information about disciplinary investigations or other related proceedings. This duty should extend to information known to the regulatory bodies and the Department of Health relating to disciplinary investigations and related proceedings, even if conducted outside the United Kingdom. Consideration should be given to the collection and retention of all information relevant to patient safety, including unsubstantiated complaints, unproven allegations and informal concerns.” The Department of Health agreed with this proposal"

Page 63 of Safeguarding Patients. The Government’s Response to the recommendations of the Shipman Inquiry’s Fifth Report and to the Recommendations of the Ayling,Neale and Kerr/Haslam Inquiries February 2007]

So, this shows the existence of a national database, the sharing of information between organisations and the crippling civil rights breaches for doctors. A doctor cannot challenge anything that is done under the Medical Act 1983. I believe the prognosis is poor as the changes have already been made by the powers that be. Supreme control is indeed here by way of information gathering and databases. In a fair world, this would not be a problem but the NHS is anything but fair.