NHS England and NHS Improvement
HSIB recommends that NHS England and NHS Improvement leads a review of risks relating to patient identification in outpatient settings, working with partners to engage clinical and human factors expertise.
This should assess the feasibility to enhance or implement layers of systemic controls to manage these risks. It should also consider existing challenges relating to the usability and practice of including the NHS unique identifier in patient identification processes, and consider technological solutions to support its use.
Summary
We thank HSIB for their report and for highlighting the distressing events described in their investigation. We agree that risks exist in relation to the identification of patients in outpatient clinics and that there is potential for mis-identification to occur. We also note that as the reports states, the scale of the risk of misidentification of patients in an outpatient setting is unknown.
HSIB’s recommendation asks for a significant programme of work to be initiated by NHS England and NHS Improvement’s national patient safety team in response to this incident. Our assessment is that this work would require determination of the true scale and impact of the risks identified, examination of multiple rather than single incidents, and examination of relevant risks in situ, including through ethnographic and other types of observational studies. Once complete, identification of meaningful and proportionate actions to address those risks would require design and iteration prior to implementation.
In all, this would be a significant and resource-intensive programme of work that is currently unfunded and so would require resources to be removed from other priorities. At this time, there is insufficient evidence that the scale of this risk would justify such a reallocation of the available resources.
We also note the reference to assessing the usability and practice of including the NHS unique identifier in patient identification processes and consideration of technological solutions to support its use. While we understand the rationale here, we are also aware of the very practical need to be able to identify patients on the basis of information they have to hand and will be able to reference confidently, such as their name, date of birth and address. We are concerned that knowledge of NHS number is not sufficiently widespread to support its routine use by patients in this way.
On that basis, the national patient safety team will not be acting on this recommendation at this time, although we will continue to lead and support a range of wider work that supports correct patient identification across settings.
Full response
HSIB’s recommendation asks for a significant programme of work to be initiated by NHS England and NHS Improvement in response to this incident. Conducting a review of risks relating to patient identification in outpatient settings, working with partners to engage clinical and human factors expertise and assessing the feasibility to enhance or implement layers of systemic controls to manage these risks would require significant resources to be invested in this work and removed from other priorities. We are also concerned that, despite HSIB’s application of clinical and human factors expertise during their national investigation, you were not able to identify any specific recommendations for safety improvement in this area. This suggests to us that the chances of success for any additional work may not be high.
At this time, there is insufficient evidence that the scale and impact of this area of risk and the likelihood of success would justify such a reallocation of resources from areas where those resources can have a greater impact on significant patient safety risks.
We also note the reference to assessing the usability and practice of including the NHS unique identifier in patient identification processes and consideration of technological solutions to support its use. While we understand the rationale here 3 and have supported and promoted the safety benefits of the unique NHS number for many years, we do not believe it is the answer at the point a patient arrives in an outpatient setting. The specific challenge here is to link the patient with their records, and robust methods of doing that have to rely on information all patients have to hand and will be able to reference confidently, such as their name, date of birth and address which in combination provide a unique identifier. Systems that relied on patients carrying or recalling their own NHS number on arrival at an outpatient clinic are likely to increase risk for those patients who will inevitably forget to bring it with them, or imperfectly recall the sequence of numbers. While increasing use of the NHS app driven by the current pandemic may be improving that situation, we are not yet aware that patient use of the NHS number is sufficiently widespread to support its routine use in this way.
On that basis, NHS England and NHS Improvement will not be acting on this recommendation at this time, although we will continue to lead and support a range of wider work that supports correct patient identification across settings, including technological solutions led by NHSX and NHS Digital, and advice and guidance on specific challenges like unidentified casualties.
We further note that this recommendation and the response that we have had to provide potentially reveals a wider system gap. We appreciate that HSIB’s remit is to deliver expert patient safety investigations and to make recommendations to bodies that it feels can act in response to the findings of those investigations. However, in this case, HSIB’s findings and recommendations reveal a need for a function that can dedicate significant resource to more in-depth examination of risks and issues following an initial investigation. There have been similar recent HSIB recommendations that in essence suggest more extensive investigations or explorations are needed to understand the issue. These require significantly more work than any single incident investigation to explore the true scale and impact of the risks identified, and examination of those risks in situ, including through ethnographic and other types of observational studies. In the absence of HSIB or ourselves being able to undertake that work then there may be a piece missing from the system response.
Having noted this, we will discuss this issue further with colleagues in DHSC.
Responses received on 27 August 2021.