We asked you to comment on the proposals for a new data standard and process to assign the correct commissioner code in commissioning data sets. The flow chart and supporting guidance was developed to provide a consistent approach for identifying the correct commissioner. This was required for cases where there may be a conflict in which code is required first, or where the commissioner may be difficult to determine, such as in Specialised care, cross border care, and military and offender health settings.
47 responses were received on the proposed standard. 100% of responses felt there was a need for a consistent and accurate Commissioner Assignment Method, and there were some positive comments in the value of having a single agreed guidance for this process and local variations observed.
91% thought that the method should be expanded to other data sets (Maternity, Children, Community, Diagnostic and Mental Health) however some comments were made arguing against this saying that it would be difficult to implement these changes in clinical systems in other areas. It was noted that in some data flows such as the Diagnostic Imaging Data Set, the commissioner code is derived in SUS, so that for the diagnostic imaging data set this could be applied in the SUS data.
The guidance was seen as comprehensive, but perhaps not as clear as it could be in all areas. 87% of responses agreed with the logic, but some potential errors were identified, particularly regarding patients living in the England-Wales border area. You emphasised that there may be local mismatches between funding and the identified commissioner in some areas, due to legacy issues.
To implement the standard, it was suggested that it could take six months to interpret and check the compliance of local systems. There was mixed feedback about the need for a tool to implement the CAM; Sample SQL code or example implementations was highly valued by respondents, however it was noted there would be much variation in the way that the algorithm would be implemented. There were some requests for peer support and networking to support implementation.
NHS England has made changes to the guidance, and published it on its website as a guidance document.
To make the guidance available to all as soon as possible, NHS England has published the 15/16 work as guidance on its website - https://www.england.nhs.uk/ourwork/tsd/data-services/. The CAM will be proposed as part of the 16/17 standard contract for NHS England to support implementation.
Thanks to the thorough feedback, errors were identified in our interpretation of the Welsh Border protocol, which has been corrected in the process. An issue was identified where the headquarters postcode of a trust may not be ideal for identifying the host CCG, and a clarification was made in the guidance to account for this. Guidance was changed to use GP Practice not General Practitioner to derive CCG. It has been acknowledged that there may be discrepancies between local commissioning arrangements and the commissioner code in the short term.
We have attempted to improve the diagram, and make certain parts of the guidance easier to follow. Some of the dependencies on other documents and processes are unavoidable, for example there is a dependency on Organisational Data Service files and the Prescribed Specialised Services Tool, these are independent services and including them would be beyond the scope of this work, and including copies of these data in the CAM guidance will make version control difficult. We will take on the feedback and improve for future versions where possible, and include links to the resources on our website.
We are looking into developing an example SQL implementation. We will be happy to talk with all survey respondents and set up a virtual network.