Information

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Information Risk Management Services
n Business Services Authority Dental Practice
Division

• Nina Monckton

www.dpb.nhs.uk 12345 MNO
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Contract monitoring

• Reporting on activity payments
• Ensuring that activity is meeting requirements
• Ensuring that system is being used appropriately
• Highlighting potential risks

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DPDs Risk framework

• Identify classify
• Establish controls
• Establish information sources
• Assess the scale of the risk and effectiveness of
  controls
• Report on issues, our activities and
  recommendations

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Risks

• Errors or misunderstandings
• Administrative or clinical
• Fraud (deliberate deception)
• Manipulating or playing the system to maximise
  units of dental activity. (Gaming)
• Risks can be introduced from any person within
  the process (PCTs, DPD, Dentists, Patients etc.)

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Examples of risk

• Overcharging patients
• Providing a band 2 treatment but putting band 3
  on the FP17
• Splitting submitting more than one FP17 for
  the same course of treatment
• Cherry picking patients or treatments
• Clinical issues

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Risk issues for PCTs and patients

• Value for money from the contract
• Access to dentistry
• (Potentially) reduced patient charge revenue
• Under-treatment
• Over-payments to contracts
• Quality of treatment below expected standards

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Data sources

• Data warehouse that holds the information from
  every FP17 processed since 1998
• Anything captured from the FP17 is available for
  analysis
• Additional processing information is also held
  e.g., where we have made assumptions about dates.
• Payments on line system
• Monitoring data

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Identifying risk in contract activity

• Monitor activity from FP17s
• Use the data to look at patterns of activity.
• Create ratios and performance indicators and use
  distribution statistics to spot the outliers.
• Use data from our processing systems to monitor
  errors on FP17s or non-compliance with
  regulations (e.g. sending FP17s more than two
  months after the end of a course of treatment)

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How data from FP17s may be used

• FP17s received per patient identity
• Rates of incomplete treatment
• Rates of continuation of treatment
• Mix of treatment types (bands)
• Types of patient treated (ages,
  exemption/remission status)
• Patient charge revenue
• Incorrect completion of FP17s
• Time taken to send in FP17s
• Time between patient treatments

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Limitations of using FP17 data

• Monitoring FP17 activity does not guarantee to
  find all inappropriate activity.
• Local knowledge is required to interpret the
  results.
• Statistical indicators are not evidence of wrong
  doing, there may be plausible reasons for
  patterns of behaviour outside an expected range.

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Monitoring activities

• Patient questionnaires
• Record card checks
• Benefit eligibility checks
• Results from Dental Reference Service

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Patient questionnaires

• Confirmation that patient exists
• How closely does the patients recollection of
  events match those on the FP17
• Patient satisfaction

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Record card checks

• Can the record card be provided?
• Does the information held on the records support
  the FP17?
• Availability and correct completion of relevant
  enclosures
• Evidence of reasons for referral

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Benefit eligibility checks

• Check whether patient ID can be confirmed as
  exempt from charges
• Check the patient declaration supports the FP17
  data
• Issue penalties and/or request repayment of
  patient charges

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DRS

• DRS will have access to statistical information
• DPD in Eastbourne will have access to DRS results
• PCTs will get a copy of the Dental Officers
  report after each visit

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What we can do

• SI 596 defines the functions of PCTs and SHAs
  exercisable by the Authority in relation to PDS
  and GDS agreements
• Make payments and provide contract monitoring
  reports
• Monitor completion of courses of treatment and
  referrals
• Request and access information (incl. patient
  records)
• Practice visits

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more specifically

• NHS BSA Directions 2006, Schedule 6, paragraphs
  2(3), 2(4), 3(3), 3(4) and 3(5) direct us to
  process, assess and monitor the information
  received in order to
• Monitor the performance of the clinic and
  prevent, detect and investigate fraud or other
  unlawful activities
• Provide monthly reports based on the processing
  of the FP17s and payments made to providers
• Provide timely reports where the BSA considers
  there might be evidence of a breach of contract,
  unlawful activity or other unusual irregularity

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Monitoring outputs

• Reports and analyses
• Support PCTs with contract performance issues
• Educate or deter those who appear to be misusing
  or misunderstanding the system

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Outputs to PCTs

• Regular reporting on activity and payments
• Regular reports on background monitoring
• DRS practice visit reports
• Updates on national issues related to risk
• Alerts to significant concerns
• Bespoke analyses
• Risk assessment
• Targeted checks
• DRS clinics

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PCT regular reports

• Summary report
• Year to date view of payments and progress of UDA
  against contracted total (Key indicators) for
  each contract
• Payment report
• Month by month breakdown of payments for each
  contract
• UDA report
• Breakdown of the UDAs achieved for each performer
  within a contract by treatment band

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PCT regular reports

• Exemption report
• Breakdown of the FP17s received by the patient
  type for each performer within a contract
• Transitional orthodontic monitoring report
• Analysis of the payments made for orthodontic
  treatment started in the old system that will be
  completed in the new system.
• Current orthodontic monitoring report
• Count of assessments, treatments started and
  treatments completed by performer within a
  contract.

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Reports under development

• Patient flow
• Analysis at PCT level of the residency of
  patients treated.
• Numbers of dentists
• Counts of performers on contracts and performers
  providing treatment.
• Referrals, continuation of treatment and
  guarantee items
• Counts of FP17s with these indicators for each
  performer within a contract.

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Reports under development

• Ethnic origin reporting
• Analysis of the ethnic origin of patients at PCT
  level
• Length of courses of treatment
• Analysis of the mean average time for a performer
  to complete a course of treatment by band.
  Including an analysis of the proportion of cases
  that were failed to return.
• Six month and nine month monitoring reports
• Incorporate some statistical indicators to give
  PCTs a feel for how contracts are performing
  compared to the rest of the country.

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Reducing risks

• Check your reports
• Are the baseline figures correct?
• Are the contracted UDA/UOA correct?
• Are the contracts providing the service you were
  expecting?
• Other sources for monitoring performance (not
  related to the DPD)

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The future for monitoring information

• Information-On-Line
• Pilot group including representatives from PCTs
  and Strategic HAs have been testing the system.
  Should be available later in the year.
• More flexible system allowing you to drill down
  into the data.
• Ideas or comments are welcome
• You are our customers, let us know what
  information you would like .

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Summary

• Get the balance right
• Enough of the right information at the right
  time.
• Allow the new system enough time to settle whilst
  maintaining an adequate level of monitoring.
• Awareness that indications are not absolute proof
  of wrong doing.