There are several changes in the imposed GP contract which have changed the goalposts for online access to medical records.
Some advice and suggestions are provided here for NHS GP practices to:
– Download searches and review 104 and 106 codes
– Download an AccuRx Florey for patients prior to having access to medical record
– Implement Practice and Patient Processes
– Let other NHS GP practices know of changes
Scroll to end of article for webinar recording and slides on this topic help on 30th May 2023.
Download searches and review 104 and 106 codes
These EMIS searches have been designed to support practices with the ongoing confusing issues around prospective record access the NHS England have been changing without adequate support.
Click here to download the EMIS searches and import them in to your clinical system
These are the searches you will see
ACTIONS
These patients have no code applied.
Includes all those newly registered.
Requires review of records – do any of these patients require a 104 code?
Do you have resources / process to review?
Consider coding all these patients with the 104 code until resources / process in place:
1364731000000104 (Enhanced review indicated before granting access to your own health record)
These are patients with existing access and under latest regulations will have their access withheld.
Consider coding these patients with:
1364751000000106 (Enhanced review not indicated before granting access to your own health record)
From the pilot sites, GP practices are advised to consider coding patients who may lack capacity.
Credit and thanks to Named GPs for Safeguarding BSW ICB (michelle.sharma@nhs.net) for creating these amazing searches!
These patients may lack capacity so under the guidance and clinical safety case, practices may want to code these patients with the 104 code:
1364731000000104 (Enhanced review indicated before granting access to your own health record)
These are patients with a code that indicates that they may lack capacity BUT have been given online access. Under latest regulations will have their access withheld on switch on date unless they are coded with a 106 code. Consider reviewing these patients and if suitable for online access to code these patients with:
1364751000000106 (Enhanced review not indicated before granting access to your own health record)
Download an AccuRx Florey for patients prior to having access to medical record
Practices should also consider how they consent their patients for online access to their medical record and if they wish their patients to consider some important points such as ensuring that patients will keep their information safe and secure, understanding that they may see abnormal results, ensuring that they are not coerced etc.
Practices are strongly advised to consent patients ideally through a custom Florey that is available to all NEL GP practices – click this link to obtain the Florey Questionnaire for Patient Online Access
To increase patient uptake, the process to obtain online codes for detailed medical record access should be made simpler for patients as well as reduce administrative burden for practices.
Implement Practice and Patient Processes
Suggested Practice Processes
- Ensure that practices have set EMAS manager to a particular date from which retrospective medical record access is available to all patients (default is 1/1/1900 for all records) – ONE OFF PROCESS
- The AccuRx Florey is set up at the practice (see above) – ONE OFF PROCESS
- Have a clear pathway for patients to request access to their medical records through the NHS App that both patients and staff understand. Promotion of the NHS App is encouraged to be advertised via the practice website.
- The patient process as below is clear to all practice staff dealing with patient requests.
Suggested Patient Processes
- Patient requests online access
- Practice issues patient with access information via AccuRx Florey
- Patient completes and returns Florey that is saved in the patients notes
- Practice will further verify the identity of the patient if required
- A code “314191000000103” (Patient registration data verified) should be added to the medical record
- Patients are either:
– given full prospective access as per the request on their application form at the point of verification (the practice would need to then review and allow retrospective access within a set time period (eg 2 weeks)
– informed that their request will be processed within a set time period (eg 2 weeks) - The practice will then review the records within a set time period (aiming for 2 weeks) and it is recommended that this is also an opportunity for clinicians to tidy up the medical record to ensure:
– The problem list is accurate with significant, active and minor problems accurately coded
– Medications are appropriate and repeat medications are correctly listed and linked
– Any data deemed confidential is marked as such
A webinar was held on the 30th May 2023 that went into detail with the issues raised in this article – here are the slides and the link to the webinar:
Could you please clarify what you mean by “These are patients with existing access and under latest regulations will have their access withheld.”? The 104 code is applied by the practice to certain patients’ records to prevent automatic future records access when the practice goes-live. The 106 code will then reinstate access (if entered after a 104 code) if the patient is later identified as not being at risk of having access to their notes. Neither code will play a role after the practice goes live (other than on a child’s 16th birthday, or for a patient newly registered who’s GP2GP transfer has come across before the practice has given the patient an online services account). So if you are recommending that all patients with a 104 code “require a 106 code” you are advising GPs to reinstate automatic access to patients who have not necessarily had their notes/circumstances reviewed. This is the same as not adding any enhanced review codes at all, which is misleading advice. Happy to discuss/clarify further!
Thanks Devin,
The advice here is for patients who have already been given online access and with the ever changing rules being applied ‘may’ have their online access blocked if they have a 104 code. So to prevent this occurring, the application of a 106 code will prevent any potential block happening. This is all still very much unclear but as guidance stands to date is the way to ensure that patients with existing access continue to have it. Please contact me via a direct contact and i’m happy to discuss specifics.
The patient is only given a 104 code if the practice wants to block automatic access to that patient’s record. The 106 code is to reinstate access (before the practice goes live) if after a review or discussion, access is actually appropriate. So under what circumstances would a patient have an unintentional 104 code? I’m also unclear on what the ever changing rules are? I’m keen to support practices to understand how best to prepare for records access and am very happy to take this offline too but I am concerned about the consequences of this information reaching lots of confused GPs…