VODG responds to NHSX Data Strategy Survey

The VODG submission highlighted issues most relevant to disability, care and support providers and the people they support.

Key points raised in the submission included:

• This strategy offers an opportunity to enable people who use services to gain more power over their lives. The strategy’s vision should also recognise that disabled people will also wish to access information to support independent living, exercise choice and control and lead fulfilled lives and that such information needs should be integrated within or alongside this strategy. How users of services, alongside providers, are therefore involved in policy implementation should be one of the first order priorities in this strategy.
• The strategy rightly points to the number of Care Quality Commission registered care providers still reliant on paper-based systems, but similar challenges exist for those providing non-registered CQC services and these are an equally important focus for any integrated approach to data. In order for the wider vision of benefiting citizens to be achieved, comprehensive support, investment and funding will be required for the full range of providers across the sector.
• The emphasis should be on data for citizens and the sector (rather than for the government as set out in the consultation). Legislation to require information from all providers (public, independent and voluntary sectors) should be proportionate, demonstrably in the best interests of those being supported and fully funded by government. Red tape and the burden on already financially stretched providers of social care services should be kept to an absolute minimum. There should be a full impact assessment of these costs which should be published.
• We are supportive of the principle around helping organisations develop the right technical infrastructure but would emphasise the need for the infrastructure to meet the needs of the diverse range of providers that exist. Significant technical and financial support will be required for the full range of providers and representative and infrastructure organisations to be able to engage meaningfully in this area of development. It is important for the voluntary sector’s contribution to be recognised, especially as some of these services are at the heart of local communities and often at the margins of statutory regulation and DHSC thinking.
• As it currently stands, the strategy lacks recognition of investment that will enable providers to implement the new IT systems that will source and store data and build the expertise and knowledge within their workforce to maintain such systems in the long-term. Equipping the whole workforce to use digital technology is key and time, money, energy and prioritisation are needed in order to deliver digital projects and keep things moving when there are difficult challenges. It is not the systems alone that makes for success but the “buy in” and collaboration of the people implementing them.
• Current commissioning practices between local authorities and voluntary sector providers are centred around commissioning by the hour, rather than by outcome. Such commissioning practice does not incentivise providers to invest in new digital solutions or explore new ways of working. The principles of this strategy will only be achieved if providers, commissioners and industry experts work together to capitalise on the opportunities that data and digital transformation presents. An inclusive approach will encourage ownership and system adoption.
• VODG supports innovative and collaborative ventures between citizens, providers, commissioners and policy makers. At present, this strategy needs to go much further. And moreover, issues of equity, diversity and inclusion need to play a central part in further development of this strategy. For example, particular attention should be given to ensure that AI innovations do not conflict with the ability for people to make informed decisions.

Dr Rhidian Hughes, Chief Executive of VODG, said:

“We also identified areas of the strategy that we believe could be strengthened in its approach and as such, have welcomed this opportunity to share our feedback. We look forward to engaging with the government and its agencies in further developing  the shared ambitions of this strategy.”