Written evidence submitted by techUK (DHS0008)

techUK is the trade association which brings together people, companies and organisations to realise the positive outcomes of what digital technology can achieve. With over 900 members (the majority of which are SMEs) across the UK, techUK creates a network for innovation and collaboration across business, government and stakeholders to provide a better future for people, society, the economy and the planet. By providing expertise and insight, we support our members, partners and stakeholders as they prepare the UK for what comes next in a constantly changing world.

Executive summary

techUK would like to thank the Health and Social Care Committee and its Independent Expert Panel for the opportunity to provide a response to inform their evaluation on progress made in digitising the NHS.

Over the past two years we have seen a significant change in the way the system engages with the supplier community and welcome the more open and collaborative approach. We recognise the excellent work of the former NHSX unit, now the Transformation Directorate, NHS Digital and other organisations across the system in working closer with suppliers to create a strong, vibrant ecosystem for digital health and care in the UK.

It is now time to build on this progress. There is a significant lack of clarity around where funding is coming from and at what level commissioning decisions are being made, as well as an apparent lack of consistency in approaches taken at local level, where we should instead see commonality with local flexibility.

Further to this, there is a lack of clarity around how commitments made in recent digital health and care strategies, from ‘Data saves lives’ to the draft ‘Standards and Interoperability strategy’, ‘National Strategy for AI in Health and Social Care’, and more, will work with one another. No delivery plans have yet been published, and timelines released so far are often pushed back with little warning. Greater clarity and regular dialogue with industry would help to ensure that all efforts are directed towards the most pressing priorities of the system. Such an approach would also build further trust between suppliers and the NHS.

Section 1: The care of patients and service users

We support ambitions to increase the availability of digital monitoring, utilising virtual wards to shift care into the home and community and thereby supporting patients to self-manage conditions. Over the past 12 months and more, we have seen remote monitoring services used across the country to great effect. Such technologies are having reducing ambulance callouts, increasing clinician contact, and helping discharge more patients from hospital. We welcome the push from NHS England to extend or introduce the virtual ward care model across all Integrated Care Systems (ICSs), which has shown significant impact in helping the NHS manage resources efficiently amidst growing challenges.

In techUK’s recent report, ‘Right from the Start’, we highlighted the opportunity for ICSs to take a broader view and adopt a fresh approach to empowering citizens, helping them to navigate local systems and gain a comprehensive understanding of available digital health technologies in their area. The recent CQC ‘State of Care’ report demonstrated that this is already happening in some ICSs, including one system in Cornwall that is working to introduce an ‘ICS in your pocket’, to transform people’s care pathways. This would be a facility to book and manage appointments, communicate with care staff, and get health and wellbeing information. It could empower residents to manage their own care, in and out of hospital, furthering the ICS’s vision of “supporting people to help themselves and each other”.

There are several factors likely to impact the ability of the government to meet commitments in this area. Below we have outlined the priority areas we think must be addressed to guarantee progress:

1. Clarity from the centre

Clarity from the government and arms-length bodies is essential to ensuring progress on commitments to improve the care of patients and service users. Lack of consistency in communicating key decisions can cause uncertainty within the supplier community, and as a result slow down innovation, impacting the market’s ability to respond.

techUK supported the outcome of the Laura Wade-Gery review, the merging of NHSX with NHS England, and next year that of NHS Digital. Having a single statutory body responsible for data and digital technology should help to reduce duplication of effort and ensure the focus is on key priorities aligned throughout the system. However, given the size of the organisations, the complexity of the projects undertaken and the importance of the mission, we recognise this will be difficult to achieve in practice, particularly in the immediate aftermath of the merger. We therefore strongly encourage NHS England and NHS Digital to continue to engage closely with industry, keeping the supplier community updated regarding changes that may impact their work, and providing a clear understanding of key priorities at NHS England and ICS level. Ultimately this is key to ensuring the sector develops solutions that support the system in addressing the most pressing challenges.

Earlier this year, announcements that pay rises for NHS staff would be drawn from existing budgets allocated to digital technology and diagnostics caused significant concern among the supplier community. Maintaining a regular dialogue with industry will play a crucial role in helping to achieve the vision set out in the plan for digital health and care and strategies preceding it.

Finally, as mentioned above, we commend the work on virtual wards and fantastic progress seen over the last 12 months. However, we believe there is a need for greater clarity of messaging around the purpose of virtual wards, as the definition is being treated as somewhat movable. Trusts and ICSs seem to be blurring virtual wards with long-term condition management, chasing the funding made available for this commitment instead of addressing the need. Funding intended for virtual wards should be ringfenced for technologies that will help discharge people from hospital, as changing central instructions to meet local needs risks creating confusion and diluting the potential impact of the intended programme. 

2. Capacity within regulatory bodies

The lack of capacity within NICE and the MHRA to approve new digital health technologies, including virtual ward companies and remote monitoring solutions, will limit the government’s ability to bring improvements to patients at pace. These capacity constraints are exacerbated by the transition from MDD to MDR following Brexit, with technologies already approved needing to be reassessed. We recognise that the MHRA is addressing challenges faced by industry. This will be key to ensuring that the UK continues to be an attractive market to develop and deploy digital health technologies, cementing our global status in the wider life sciences space.

3. Detail on funding commitments

In the past year, funding has been announced to support people to manage conditions more independently and outside of hospital settings. Greater clarity is needed on where this will be allocated and what the different pots are set to be used for. A body such as the Accelerated Access Collaborative could play a significant role in clearly setting out the different avenues available to digital health and technology innovators, and who is making commissioning decisions. It is unclear which decisions have shifted to a regional level, and which are driven by the centre.

Section 2: The health of the population & Data for R&D programme

techUK has made clear, in our ‘Ten Point Plan for Healthtech’ and more recently in ‘Right from the Start’, that we must equip the public with the right tools and information to take control of their health and participate in their own care. Digital technologies have already demonstrated great potential to help achieve this, both through small-scale programmes across the UK and international examples. The Data for Research and Development programme is an encouraging piece of work with the potential to radically improve the UK’s use of health data. While the technology and digital health industry is supportive of commitments outlined so far, there is scope to be even more ambitious.

1. Further detail on existing policy commitments, including the implementation plan for Data saves lives

techUK welcomes recommendations made in the Goldacre Review and subsequent ‘Data saves lives’ strategy. However, further detail is needed on how the commitments will be carried out. For instance, there is a tension between existing Trusted Research Environments (TREs), some of which are unlikely to meet incoming specifications for Secure Data Environments (SDEs), as well as with plans to create between one and three national TREs. Further detail is also required regarding the necessity that SDEs can interoperate. Given that there will be ten separate regional solutions with prior architecture in place, further consideration on how this will be carried out is needed, and requirements for those looking to provide the platforms made clear. Funding will also need to be made available to support staff with training to maximise capabilities of SDEs to improve clinical care.

The previous Secretary of State for Health & Social Care set out that the government “will work with the public, including people working in health and care, to develop a new pact on data, which will set out how we will use health and care data and what the public has the right to expect”. Confirmation that this ‘pact on data’ is still a government intention, as well as more detail on what it will entail will be welcomed by industry, as well as helping to secure public confidence.

The implementation of these commitments must carefully consider the way in which they are communicated to the public. A continuing lack of understanding amongst the public about what their data will be used for continues to engender a lack of trust. Using existing channels of communication to provide clarity on this is essential.

Finally, although the breakdown of commitments around data for research and development is welcome, progress would be aided by an outline of which body is responsible for delivering on each of these priorities and how success will be measured.

2. Disconnect between central and sub-national plans

As with several other commitments on digital health, there seems to be a disconnect between central and sub-national plans for SDEs. Anecdotally, our members are hearing that ICSs feel they each need to build their own SDE, often without the requisite technical capabilities to deliver such an ask.

Clarity on local versus central decision-making will help foster the environment necessary for innovation. Any implementation strategy should seek to reflect best practice already underway, harmonising benefits where these have already been achieved. There is a concern among industry that progress made at a local level may be lost in the transition to a nationally led programme. 

Section 3: Cost and efficiency of care

As shown throughout the COVID-19 pandemic, significant advances in science and technology have brought demonstrable benefits to the NHS and frontline staff, helping to achieve more efficient care and better outcomes.

However, selling technology to the system has long been a challenge for industry, an issue recognised not only by the supplier community but also by digital leaders within the system. Multiple attempts to simplify the commercial landscape have not yet led to the widespread change the sector needs.

With NHSX, and soon NHS Digital, incorporated into NHS England, and with ICSs now on statutory footing, we have a significant opportunity to streamline processes and reduce the complexity that comes with working with the NHS. Ultimately, this will help to deliver better value for the taxpayer whilst also strengthening the UK’s growing healthtech ecosystem.

1. Focusing on early market engagement

It is often thought that health and care organisations cannot engage with technology suppliers to understand the art of the possible, but closer working can help both sides understand the other’s perspective. For suppliers, this means better knowledge of what the health and care system need and the issues it is facing. For the public sector, this means gaining a view to the solutions that could be used to help address those challenges.

We have seen significant progress in recent years, for instance, through NHS Digital’s programme of industry engagement. We strongly believe this should be expanded, making regular engagement with industry an integral part of NHS work. In ‘Getting IT Done: techUK Public Sector Supplier Perspectives’, our Public Sector Board recommended setting up regular innovation sessions to help foster engagement.

Although the use of pre-tender engagement mechanisms has increased, we struggle to see consistency across the system. Although we recognise this is difficult to achieve given the complexity and makeup of the NHS, there is a need for guidance from the centre via the new Central Commercial Function (CCF). This would help to carry forward the open and collaborative approach we saw throughout the pandemic.

2. Addressing challenges resulting from the proliferation of frameworks

While industry is supportive of the use of frameworks, there are several long-standing concerns:

1. the number of routes to market that suppliers must be aware of
2. the cost of getting on these frameworks and burden this poses for SME
3. the fact that so many of these frameworks overlap.

This as a substantial concern, not only for smaller companies, but also for some of the biggest companies that work with the NHS. techUK welcomes the work undertaken by the previous Procurement Target Operating Model (PTOM) programme, now the CCF, in setting out guidance to trusts for buying digital and IT goods and services in the NHS. We welcome further engagement with industry to understand how the guidance has been applied across the system, the impact so far, and how we can build on this going forward.

3. Embedding standards as part of frameworks

The work undertaken by the PTOM programme sought to provide clarity on the minimum standards applicable in frameworks according to each of the six pillars used to sub-categorise the digital space. We welcome this approach and the transparency with which it has been communicated to industry.

Going forward, we welcome regular dialogue between the centre and industry so that suppliers can prepare accordingly and ensure that they are not caught out by planned changes.

Further clarity is required on interoperability and data standards, work we recognise is being addressed in the upcoming version of the standards and interoperability strategy from NHS England.

Nov 2022