Health Records – Online/Electronic Access

Online access by patients

Online access to health records by patients appears to have much wider associated risks and potential workload for practices than the transactional on-line services of appointment booking and prescription ordering.


NHS England has confirmed that practices are not required to offer online access under their contract to all their registered patients, and also it is a local practice decision whether online services should be available to children in their own right under the age of 16 years.
 

LMC advice to practices is that they initially offer on-line access only to a cohort of patients who are less likely to present any eligibility concerns to practice staff and, therefore, are less likely to create additional workload, whilst practice staff gain confidence in the process.  Clearly, and for the purposes of differentiation, it should be noted that the LMC’s advice is based on a different underlying approach to that of NHS England.
 

The following advice has been obtained from NHS England:


Risk of coercion/vulnerable patients – Practices will already have processes in place to identify suspected coercion relating to other interactions with patients.  Online access adds a further dimension to these but the signs and behaviours of patients suspected of being coerced will be similar.  General guidance is already available to the profession from reputable sources, including the RCGP.  In addition to these the RCGP publication Online Services: Coercion Guidance for general practice is under review but is not expected to change significantly.  The patient information leaflet for online records access highlights the risk of coercion to patients.


Patient challenges to content of record – A number of practices are providing patients with online access to the full record which is more than the current GMS requirement.  We have not received any reports of patients challenging the content of their record which resulted in the level of access being reconsidered.  We do have documentary evidence that allowing access to the full record has improved data quality.


Proxy access for patients who lack capacity – Although NHS England does not have any detailed information on whether proxy access has been granted for parents/carers/guardians on behalf of patients who lack capacity, we do know that proxy access is being used for patient online services.  To date, we have not had any specific concerns raised about this.  The RCGP guidance is that access is granted to the applicant only if the GP considers that it is in the best interests of the patient.  A judgement would need to be made on a case-by-case basis of the benefits vs risks or challenges to supporting the request.  It may be that the clinical advantages clearly outweigh the risk involved.


Requests for access by those under 16 years of age – If requested, by the parent/guardian, access to a child’s online services, including access to records, can be granted up to the age of 11.  Between the ages of 11 and 16 the parent/guardian can continue to have access with the child’s consent if the child is deemed competent by his/her GP.  The child can also be granted access.  It is a local practice decision whether online services are available to children in their own right under the age of 16.  On reaching the age of 16, parental access ceases and rules governing access for adult patients apply.


Practices need to agree their policy on providing online services to their patients and this should be in a written form with all staff made aware of it, and any subsequent changes to it. 

 

Principles for sharing local electronic patient records for direct patient care

Until relatively recently, data recorded in GP systems have not been directly accessible by other organisations. Data have previously been shared via specific clinical communications, for example, by sending a referral letter.


A number of system suppliers have developed systems which allow healthcare professionals from different organisations to directly access the detailed GP record.


Guidance is available on the GPC website on how to make patients aware of new arrangements relating to the management of their health records, establishing organisations involved in sharing, options for sharing and restricting information, legitimate relationships and audit trail.

 

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Updated on Wednesday, 23 October 2019

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