Federated Data Platform Check and Challenge Group – minutes and action notes: 19 September 2025

Organisational attendees

  • National Voices
  • Understanding Patient Data
  • Royal College of General Practitioners
  • Association of Medical Research Charities
  • NHS England
  • NHS Healthwatch
  • Patients Association
  • British Medical Association
  • Office of the National Data Guardian
  • UNISON
  • East Kent Hospitals NHS Foundation Trust
  • Federated Data Platform (FDP) Programme team (NHS England)
  • Academy of Medical Royal Colleges

Apologies received

  • National Data Guardian
  • Information Commissioner’s Office (ICO)
  • Newcastle Upon Tyne Hospitals NHS Foundation Trust
  • NHS Confederation

Open Actions

Action IDDescriptionOwnerTarget date
CAC-098
The deputy director of product to present updated user interface (UI) designs at a future meeting.FDP Product team17 October 2025
CAC-A96
FDP Programme team to bring an update on the population health management development to a future FDP Check and Challenge meeting.FDP Programme team17 October 2025
CAC-099
Technical testing needs to be included in HDS to ensure technical teams conduct tests to verify the portability of the CDM data.FDP Programme team
21 November 2025
CAC-100
FDP Programme to consider refining the definition for the sixth use case to ensure clarity and transparency.FDP Programme team21 November 2025
CAC-101Stakeholder engagement – the FDP delivery director to engage with internal NHS governance groups and the Cabinet Office for feedback on the proposal for a sixth new use case.FDP Programme team21 November 2025
CAC-083FDP Programme team to share overview of benefits, particularly in relation to staff morale and satisfaction, for the Timely Care Hub Product.FDP Programme team19 December 2025

Meeting minutes

Welcome and introductions

The chair opened the meeting. Apologies were noted.

The chair acknowledged that the ICO representative had moved roles and wouldn’t be attending in future, with a replacement pending. 

No conflicts/declarations of interests raised.

Minutes and actions from previous meeting 

  • The group approved the July 2025 meeting minutes, subject to minor amendments (changes to chairing and apologies).
  • The chair requested that the June 2025 meeting minutes be recirculated for further approval, with a request for the group to respond by 26 September 2025 if any amendments were needed.

Action log review

  • Strategic value logic model: closed as on the meeting
  • Timely Care Hub Product benefits: arranged for a later
  • Population health management development: scheduled for the October 2025
  • User interface designs: scheduled for the October 2025
  • Technical testing inclusion in HDS: scheduled for November 2025
  • Sixth case use deep dive: scheduled for November 2025
  • Stakeholder engagement on feedback for the sixth new use case: scheduled for December 2025 meeting.

FDP and PET Programme update 

The director of data management and transformation presented an overview of the FDP and PET Programme to date, and the following highlights were noted: 

  • As of 18 September 2025, it was reported that 149 trusts had signed up for the
  • 41 of 42 ICBs had tenants, with ongoing work noted to align with new ICB
  • The programme has seen a strong demand for Cancer 360 and Shared Patient Tracking List (PTL) products.
  • The System Coordination Centre (SCC) product had now become generally available across the programme.

The group received and noted the update.

Communications and engagement update 

The FDP lead senior communications and engagement manager joined the meeting and provided an update on the current developments surrounding the FDP, including the following: 

  • Stakeholder/media attention around suppliers
  • It was noted that NHS England were maintaining messaging on transparent procurement process and remained focusing on highlighting benefits from the FDP Programme.
  • There are plans to develop more public animations and layered website content to address privacy/security concerns.
  • The team was collaborating with the Kings Fund to broadcast a podcast to address further FDP queries.
  • There are plans to develop a live dashboard for product adoption visibility. 
  • Data protection impact assessments (DPIAs) and meeting minutes publications were ongoing.

The following comments and queries were captured by group members: 

  • Members challenged the importance of addressing both benefits and risks of privacy and security in communications, acknowledging the need for a careful balance. It was noted that with the public animation being developed, content would be tailored for different audiences based on feedback from patient panels. Members agreed that this layered approach would be beneficial.

Action: once finalised, members requested that the animations be shared with the group.

  • In regard to the development of the FDP podcasts, members highlighted the importance of including early adopter sites to outline change management details. The FDP lead senior communications and engagement manager confirmed this was the intention and agreed to reach out to the group for further ideas and topics.

Action: email the group to request suggestions for the upcoming podcast sessions. 

The group received and noted the update.

AI discharge summary tool 

The FDP assistant director of product, FDP senior delivery manager and the forward deployed systems engineer joined the meeting. 

The group were updated on the progress of the product, which was being developed in partnership with Chelsea and Westminster NHS Foundation Trust, and FDP. The group acknowledged the benefits, enablers, challenges, product vision, and the anticipated delivery timeline. 

The forward deployed systems engineer provided a demonstration of the product, outlining the tool’s interface and its functionality. The demonstration showed how clinicians could generate, review, and edit AI drafted discharge summaries, with clear referencing to clinical notes and multiple validation steps to ensure accuracy and safety. 

The following observations and challenges were fed back from group members: 

  • Members challenged the design of the AI discharge summary tool, questioning whether the tool had been classified as a medical device by the Medicines and Healthcare products Regulatory Agency (MHRA). 1 GP member expressed particular concern on the product being considered class 1. The group escalated the risk of loss of clinically relevant information, noting examples where any omissions could affect ongoing care and safety. Another member highlighted that the use of patient data to validate and re-validate a tool under development does not clearly fall within the scope of direct care and that careful consideration is needed to determine if this is within the reasonable expectations of patients.
  • The group stressed the importance of transparency and traceability, referencing British Medical Association (BMA) motions carried at a Special Representative meeting on 14 September 2025. BMA policy, which was shared. It was outlined that there was a requirement that AI generated records needed to be clearly identifiable, with explicit patient consent and a “MHRA yellow card” identifier for incident.
  • 2 members further queried whether the tool’s development and validation (currently at Chelsea and Westminster Hospital) should be classified as direct care or research/analysis, noting the regulatory and consent implications and emphasising the need for clear DPIA documentation.
  • The group cautioned that the tool, as presented, needed further clinical depth and regulatory assurance, and called for visibility of further evidence of safety, clinical appropriateness, and formal regulation before further deployment.

The presenting team acknowledged the points raised and responded as follows:

  • The team confirmed that discussions with the MHRA regarding medical device classification were ongoing and that regulatory requirements were being considered throughout the development process.
  • The team emphasised that the tool was designed to support, not replace, clinical judgment, with multiple validation steps built in to mitigate risks of information loss.
  • The team reiterated that discharge summaries remained clinician led, with the AI functioning as an assistive drafting tool rather than an autonomous decision maker.
  • In regard to transparency, the team noted that traceability features and clear documentation of AI involvement were being actively explored in line with emerging policy requirements.

In summary, the chair acknowledged that members had raised a number of important challenges and considerations. The chair highlighted challenges regarding the human implementation aspects of the product, noting the risks of increased pressure on resources and the potential for corners to be cut.

The presenting team welcomed the challenge and agreed to continue refining the product, governance, and assurance processes, acknowledging the evolving regulatory landscape for AI in healthcare and to keep the group informed.

Action: the group agreed it would be helpful to invite a representative of the MHRA to a future meeting and discuss AI usage in NHS England.

Strategic value logic model

The FDP product lead and FDP deputy product lead joined the meeting and presented the Strategic value logic model, a framework linking NHS strategic priorities to operational and tactical metrics to ensure FDP product development delivers measurable impact. The group noted its structure, its use in assessing new product ideas and identifying portfolio gaps, and its role in guiding investment decisions. A demonstration of the tool was provided, showing how users can drill down from strategic metrics to operational needs and identify areas for prioritisation.

Due to time constraints, the chair agreed that the slides would be circulated after the meeting to capture any additional comments from the group. Action.

Any other business (AOB) and close

No AOBs were raised.

The Chair highlighted that the next FDP Check and Challenge meeting will be held on Friday 17 October 2025.