From October 2021, amendments to the GMS and PMS regulations came into effect, bringing in to force a number of the agreements reached by NHS England (NHSE/I) and the British Medical Association (BMA) General Practitioners Committee (GPC) England in previous negotiations and published in January 2021 in Supporting General Practice in 2021/22. These new requirements were originally signalled and agreed in January 2019 as part of a five-year deal, published in Investment and evolution: A five-year framework for GP contract reform to implement The NHS Long Term Plan.
This explanatory guidance outlines the updated digital service requirements and provides links to other useful information, with the aim of helping GP practices to meet these, and of helping Integrated Care Systems, Clinical Commissioning Groups, Primary Care Networks and others to provide effective support to GP practices in meeting the requirements.
- New functionality for patients
- Online consultation tools
- Availability of online consultation tools
- Use of online consultation systems
- Providing video consultations
- Secure electronic communications
- Use of relevant software to deliver the above new services
- Data reporting
- An online facility to provide and update personal or contact information
- Signposting patients to your online consultations tool and the NHS Symptom Checker from your website or other online presence
Practices are now required to “offer and promote” to their patients (and those acting on their behalf) the following:
- an online consultation tool
- a video consultation tool
- a secure electronic communication method
- an online facility to provide and update personal or contact information.
These requirements are all subject to existing safeguards for vulnerable groups and third-party confidentiality. They are to be in place alongside, rather than as a replacement for, other access and communication methods, for example, telephone and face to face contact.
The aim of online consultation tools is to provide increased choice and flexibility for patients in how they access care, and to also provide benefits to practices in managing and prioritising their workload.
All practices must offer and promote to patients the ability to access and use an ‘online consultation tool’. By ‘online consultation tool’, we mean a software system that enables patients to make contact with their practice online and seek health advice, describe their symptoms, ask a question, follow up on a previous issue, or make either a clinical or administrative request.
This functionality is the minimum required, but the online consultation systems generally provide additional functionality. For example, many online consultation systems also include the ability to send a message to a patient as a reply to their query or request, or to ask the patient for further information. The exact tool to be used and the precise functionality provided beyond the minimum is for practices and commissioners to determine.
The online consultation tool can, but does not have to, incorporate functionality to support the other requirements listed in this guidance, i.e. to act as the online facility through which patients can provide and update personal or contact information; to act as the secure electronic communication method for the practice; and/or to provide a means of conducting video appointments / consultations between patients and clinicians.
Practices should respond to patient enquiries and information submitted through the online consultation tool based on clinical judgement and in a way that is appropriate for the patient’s needs, i.e. care decisions should be based on the patient’s clinical and other needs, not on the method that the patient has used to submit a query or request.
As practices must ‘offer and promote’ the online consultation tool to patients during core hours, patients should therefore be able to conveniently find and use the tool and it should be available to them to use.
Where practices choose to have the online consultation tool available to patients both in core hours and out of hours, this provides a more consistent experience for patients and their carers – similar to the way in which practice websites are always available and the NHS App can be used to request a repeat prescription at any time.
This approach also supports access to general practice services for patients with patterns of work or other circumstances that make it difficult for them to initiate contact for routine queries during core practice hours. Urgent care needs out of core hours should continue to be channelled via 111 or Out of Hours services.
Practices are not expected to respond to queries received via the online tool outside core practice hours, in a similar way to how practices manage blood results and clinical correspondence received outside core practice hours. There should be clear communication with patients so that they understand the likely response time to their request.
The various online consultation tools offer different functionality to support practices with triage / navigation of patient requests, local signposting and self-care advice, as well as configuring response times to suit practice business processes. Practices and PCNs are encouraged to consider the type of functionality that would best suit their needs.
Enabling patients to share written information about their symptoms or other request, online tools support practices to understand patients’ needs in advance of a consultation, making it easier for advice or care to be provided by the right person, at the right time, and in the right way. Their use can help practices prioritise care based on need, allowing non-urgent work to be spread out over a longer timeframe. They also support straightforward requests to be dealt with more quickly, for example using a pre-written message, while more complex requests can be understood before a consultation takes place, with the patient booked directly into the right type of appointment with the most appropriate clinician.
Additional functionality, such as the ability for patients to send photographs or for practices to proactively ask for information from patients (e.g. in relation to long-term condition reviews), is not contractually required of the tools, but may be beneficial in helping ensure patient needs are understood and appropriately met. The tools can also support patients in finding appropriate self-care information and advice, and there are further potential benefits in easily referring patients to other care settings or services that are appropriate to the patient’s needs, or to the urgency or timing of the request.
Many practices have found that using an online consultation tool can deliver significant benefits for both patients and the practice. These benefits are most likely to be achieved when the practice has actively adapted the use of the tool to meet local needs and has considered and adjusted workflows, rotas, appointments and communication with patients to support the new ways of working. We recognise that practices need time and support to go through this change process. There is no ‘one size fits all’ model, and practices are encouraged to co-design an appropriate model with patients and staff that meets local needs. There is funding available to integrated care systems (ICSs) to provide practices and Primary Care Networks (PCNs) with support to implement changes.
Practices must offer and promote to their patients the ability to take part in appointments / consultations by video call.
Video consultations can be particularly beneficial in certain scenarios in comparison to other remote consulting methods, including telephone appointments. There may be particular benefits arising from video consultations for some patient groups, such as those who find it difficult to travel to the practice due to frailty or reduced mobility.
Video consultations should be available and promoted, but they are not mandated in any specific circumstances. How care is delivered for any particular patient or for any specific request should be judged based on clinical need and taking into account the circumstances and preferences of the patient. For example, if a patient has requested a video consultation but the clinical opinion is that those symptoms require an in-person examination, then a face-to-face appointment should be offered.
Software to enable video consultations should be free for the patient to access or download and use on their own device, and the cost of a video call should be no more than it would be to call someone else in that local area; in other words the usage should be free other than the normal use of data which will be the patient’s responsibility. If a patient is unable to take part in a video consultation due to cost of data, lack of a device or any other reason, then an alternative care option should be provided.
Practices must offer and promote a relevant electronic communication method that allows both the practice and the patients to digitally communicate with each other in writing.
This communication method can be used by the practice to contact patients or respond to patient enquiries and questions where an online, SMS or other type of electronic message would be most appropriate. For example, a practice could use an electronic messaging systems to provide follow-up links to online information after a face to face appointment, to ask for information from a patient in advance of a long-term condition review, to respond to routine questions or enquiries from patients, to send reminders of upcoming appointments, or to communicate with patients about changes or news concerning the practice.
The secure electronic communication method could be incorporated into the same software tool as other functionality mentioned in this guidance, or it could be a stand-alone system. It should be used to support communication between patients and practices where that will increase convenience for both parties.
As per the new video consultation requirement, there is no requirement to use electronic messaging in any specific circumstances – if it is not clinically appropriate to communicate with a patient in this way on a specific occasion, or if it is otherwise not appropriate to the needs or circumstances of the patient, then an alternative method of communication should be used.
The software that practices use to provide the requirements discussed above must be of an appropriate quality, meeting all relevant standards.
The software is of an appropriate standard if it meets the relevant requirements that are set out in Securing Excellence in Primary Care (GP) Digital Services: The Primary Care (GP) Digital Services Operating Model 2019-21 (or subsequent versions of this document), which covers the policies, standards and operating procedures that CCGs are obliged to work to and apply to the provision of digital requirements under the GP contract.
Relevant standards include but are not limited to:
- technical cyber security, including encryption
- authentication measures (to confirm patient and staff identities)
- information governance – data processing standards, patient proxies
- patient / clinical safety.
Funding for digital systems and infrastructure is passed to CCGs to provide digital products and services for practices via the terms of the GPIT Operating Model.
The Digital Care Services catalogue has been established to provide assured products for use in general practice (via one of the two frameworks currently in place under the catalogue – the GPIT Futures framework and the Digital First Online Consultation and Video Consultation framework). Products listed on the catalogue have been subject to assessment by NHS Digital and have been assured as complying with relevant standards. In addition, NHSE/I and NHS Digital provide support for management of any serious incidents that arise in relation to products listed on the catalogue and broader contract management support.
If a practice uses software for digital capabilities outside of the catalogue, the practice will need to be able to demonstrate that this software meets the same or equivalent standards. Responsibility for incident management and contract management for these products in this instance would also fall to the practice.
The Department of Health signed an agreement with Microsoft in June 2020 that gives NHS organisations with NHSmail access to Office365 capability, which includes MS Teams video conferencing functionality. As a result, many NHS organisations are using Microsoft Teams as a video solution – particularly for internal meetings, stakeholder engagement and professional to professional discussions, but also in some cases for clinical consultations with patients. However, no national assessment or assurance has been done in relation to the use of MS Teams as a VC tool in a clinical setting, and so usage for this purpose must be based on local assurance and local consideration of any risks and necessary mitigations.
All NHS digital, data and technology services should achieve the Data Security Standards required through the Data Security and Protection Toolkit (DSPT). Practices are reminded that they should use the full Data Security and Protection Toolkit to understand how to meet the National Data Security Standards and submit an annual return.
If a practice chooses to use NHS Mail and SMS as part of their secure communications, practices will need to use the encrypted mode for NHS Mail and ensure completion of Privacy Impact Assessments (PIAs) when SMS is used for sensitive patient communications (as per the GPIT Operating Model).
Data relating to the use of online consultation tools and video consultations in anonymised form must be provided to NHSE/I. This data helps NHSE/I, CCGs, PCNs and practices to develop appropriate approaches to service improvement, support and use of funding.
Suppliers of online and video consultation capability through the DFOCVC framework are contractually obliged to provide this data to NHSE/I and so practices do not need to undertake this directly. However, for products procured outside of this framework, practices are responsible for providing the data described here.
Practices must provide an online method for patients to inform the practice of their address, contact details or other demographic information and to inform them of a change to any such information.
There are many benefits to practices and patients in ensuring personal and contact details are up to date, including reduced risk of personal or confidential information being shared incorrectly. Having an ability to do this online can be more convenient for patients, whilst GP practices can expect a reduced administrative burden and fewer transcription errors. Many patients do not know they can update their details online as an alternative to visiting the practice or using the telephone to request changes.
Practices can use any of a number of ways to achieve this, including: through the practice’s online consultation tool; via existing GP online services; using a webform on the practice website; via the NHS App; or via a patient-facing email address.
There is more detailed guidance that outlines how these options can be used, case studies, and help with how to comply with legal requirements including GDPR.
Signposting patients to your online consultations tool and the NHS Symptom Checker from your website or other online presence
Every practice must ensure that on its website or other online profile (such as on social media sites), they have links to direct patients to their online consultation tool and to the NHS symptom checker.
These must be displayed prominently on the home page (or equivalent) of the website or profile.
There are additional requirements regarding what information practices should have on their websites (or equivalent) as set out in existing Regulations. The GP websites and online presence: guidance for practices sets out what the existing requirements are and provides best practice on how to optimise practice websites.
Additional resources to support practices and commissioners can be found on the Digital Primary Care pages on FutureNHS (login required).