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Use case initially raised by Ian Anderson, Director of Legal Services and Partnerships at Hull City Council.
This relates to coroners/medical examiners being able to access information from GP and hospital systems to certify death.
We have consulted the IG lead within HNY who has indicated that the IG aspects for deceased patient records being accessed by MEs is currently covered by s251 until they become a statutory function.
The requirement would include resolution of the following dependencies, the first three of which are external dependencies:
A decision from NHSE to enable access to GP Connect records for deceased patients.
The necessary changes to processes and death protocols within GP systems
A gap analysis of data in GP Connect and from other providers vs data required by MEs and coroners
Application of suitable RBAC to control who has access to these records
Requirement outlined by Hull CC:
The medical examiner/coroner hospital and community system change. This has already been introduced in hospitals for the certification of death and is intended to move into the community from April. Unfortunately practice at hospitals is not meeting the required standards and this is likely to worsen in communities. Death certification submitted is not in acceptable to the Coroner as causes of death are unclear, incorrectly described, or simply wrong. This has had the impact that bodies are unable to be progressed to cremation, autopsies are delayed and the mortuary is blocked. We have had to expand the mortuary to deal with the delays. The hospital was funded to provide this service, however, practice has been that doctors undertaking this service frequently change and spend little time on it. In addition, GPs are not seeing patients in the community, or more importantly care homes, and therefore cannot certify death. It is acceptable for a GP to certify death where they have seen a patient – even virtually – within 28 days of the death, but not otherwise. The reduction of GP visits to Care homes and limited use of video links is anticipated to create greater challenge without a shared programme to address this. We have had situations where the Bereavement manager has attended hospital to chase down a doctor to get a death certified correctly on the day of the funeral and other occasions where the funeral has been delayed. The Medical Examiner needs access to the GP records and hospital records in a form that they can use to certify death correctly. Ideally GPs see patients, at least virtually on a monthly basis. The inexperience of those asked by the hospital to fulfil the role of ME is a major problem. There have been many calls to the Coroner’s staff to ask for advice on completing the forms/cause of death. When this passes into the community, with the limited capacity of GPs to answer calls, in the next couple of months there is significant concern that the situation will become even worse. Using the YHCR to present the information needed to the medical examiner with guidance on completing the new certificates will help prevent an immediate problem becoming a crisis. Given this is a national problem that is being taken up with the Chief Registrar and the Chief Coroner, developing a model locally now has significant potential.
We have been discussing this with our Practices. The patient remains live on SystmOne and EMIS until the Practice "deducts" them i.e. notifies Primary Care Support England. Most Practices like to do this quickly due to the risk of deceased patients being sent SMS or recall letters. Obviously this would be hugely distressing to the deceased family members. With the current system of using the eREFs system to notify the ME of a death via Advice & Guidance (A&G) and supply 3 months clinical data this is still a risk as you cannot use the eREFs system after a patient has been deducted. Therefore Practices are starting the A&G referral on eRefs and only deducting the patient after the A&G referral has been acknowledged. Only then are they actioning the deduction to Primary Care Support England. We are trying to clarify if Practices can still record feedback from A&G in clinical systems after the patient has been deducted.
Thanks for this update interesting. I spoke to ME about access to Derbyshire ShCR and we do not have the required information in the record as our GP data comes from the MIG. The other issue is that the closure of a record is dependant upon when the GP practice notifies the spine. There is no actual defined timeframe to allow for any test results that need adding if taken immediately before the person died etc. some records close within 2 days and another 2 weeks. When someone dies, a trained healthcare professional needs to verify the death to confirm that the person has died. This is known as 'formal verification of death'. A doctor also needs to certify the death by completing a medical certificate of cause of death. Verification and Certification are different things and sometimes carried out by different professionals if the verifier is unable to certify as well.
Thanks for the update on this one Marc
Hi Tara,
Quick update on this one.
I've spent some time reviewing the use case for providing Medical Examiners and Coroners with access to the shared care record. It appears that access to the shared care record would only be useful if GP data is made available.
We have a complication in that GP Connect do not currently share data for deceased patients. Furthermore, they've indicated they are unable to provide access to deceased patient data for the April deadline when ME and Coroners should be provided with access to primary care records. They have indicated the legal basis for providing Medical Examiners and Coroners access contradicts the legal basis for accessing records via GP Connect.
I have asked them to confirm if there is a timeline for resolution of this issue and am waiting to hear back from them. Will keep you updated as things change, but this one is blocked for now.
There is a further use case for RBAC that includes deceased data: acute Infection Prevention and Control teams investigating potentially hospital acquired serious infection which may have involved fatality. Appreciate there are many dependencies.
there's clearly a LOT to consider in this and I'm not sure if Interweave are able to do very much at this stage with the dependencies identified:
NHSD approval to use GPC for deceased patient record access
details of the acute data required by the ME, in addition to data in GPC
a full discovery exercise which ensures that a proposed digital solution has buy-in from the ME's, is useable, and will be used (the process dependency mentioned)
Attached is an options analysis of data sources that have been considered nationally and provides context and creates a picture that this is a use case that other partners may also look to the shared record for support with.
A query was also raised by Hull Safeguarding Team around access to deceased patient records. They may need to view information after death for certain cases. They queried whether when a patient dies would the information still be available (both GP connect and YHCR) or whether there would need to be a specific role enabled for them to be able to access.
Process map attached - shared by Ian Anderson.