Record migration is the process or result of migrating (or converting) records from one data format, or system, into a different format, or system. This article focusses on the movement of patient records:
- between practices, with same or different clinical systems
- in bulk, to a new clinical system or when practices close or merge
- into storage with Primary Care Support England (PCSE)
The paper records of actively registered patients are mainly stored securely at the GP practice where that patient is currently registered. Some practices, however, do store records securely off site due to capacity issues. Electronic records of those registered patients are stored centrally by system suppliers, not locally, on the computerised clinical system.
Plans are currently underway to digitise paper records (Lloyd George records) with a nationally planned digitise on demand service.
Primary Care Support England stores NHS GP medical records for people who are no longer registered with a GP in England, for example patients who have moved to another UK country, moved abroad, registered solely with a private GP, no registered with another GP when their practice has closed, or who have passed away.
The up-to-date timescales for retention are covered in the Records Management Code of Practice.
Transferring individual patient records
The current General Medical Services GP Contract requires GP practices to use a service known as GP2GP for transferring electronic health records (EHRs).
At present, a patient’s new and old practices need to be in England for GP2GP transfer. There is as yet no mechanism to send electronic records between the different countries of the United Kingdom. Where there is no GP2GP provision, electronic records are printed by the holding practice and sent as paper records to the receiving practice. There is currently no nation-wide service for this.
The PCSE process for individual patient migrations (or ‘deductions’) is currently triggered by the patient’s registration at a new practice. The electronic record is sent via GP2GP, if both practices are in England, and the follow-up manual process moves the remaining paper records, i.e. the Lloyd George envelope, to the new practice by following the guidance here.
Record deduction needs to be done on a regular basis (suggested weekly) to ensure new practices have complete records quickly. This currently entails triggering the electronic transfer and packing and returning the paper records to PCSE. This will change as the programme to fully digitise patient records progresses.
Be aware that not all data may be migrated with a transfer, for example previous deductions.
Bulk transfer of patient records
Practices must supply a detailed business case to justify a migration to a different clinical system. The commissioning organisation will assess the application and if appropriate, approve and confirm funding to support the migration.
The wholescale migration of patient information can be necessary for several reasons, i.e.GP practice closure, GP practice merger, or change of clinical system.
NHS Digital has produced a clinical system migration guide which includes an important list of pre-migration tasks. Practices should use the guide to help inform the process and support them through the challenges.
When planning wholesale migration, consideration also needs to be given to the impact on the receiving practices, their staffing, premises, etc. In some circumstances there may be one-off financial support available to recognise the impact on the receiving practice.
If receiving practices feel they cannot accept any more patients, then a temporary hold can be placed on new registrations. This is known as a ‘closed list’. Practices cannot make these decisions autonomously. They must formally apply to close the practice list if their workload is affecting their ability to provide safe care for the registered patients, or to conduct contractual obligations to meet their patients’ core clinical needs. The British Medical Association (BMA) provides guidance to help GPs decide whether they should formally apply to close their lists.
NOTE | If all local practices are full the local Integrated Care Board (ICB) has an obligation to find a practice for patients to register with.
Practice patient lists can be managed in two ways.
To ensure patients continue to access primary care services they can be dispersed through a managed process and distributed to an alternative neighbouring practice or practices where they will be automatically re-registered.
Integrated care services (ICS) will support practices to manage this process and will advise patients by letter informing them of this decision. Any patients outside the practice catchment area are asked to register with a local practice of their choice. Alternatively, the receiving practice may accept patients as out of area registrations.
When considering a practice closure, advance notice must be given to all the practice’s current patients. Arrangements need to be made for the continuing care of those patients, including the transfer and proper management of all patient records.
Records cannot be transferred until an attempt has been made firstly to give patients the choice to register elsewhere, and secondly to notify the patient of the impending transfer.
Key considerations in managed dispersal
Key considerations in managed dispersal include:
- Patient communication | There may well have been opportunities for patient engagement prior to the closure but if there is insufficient time, then all patients must receive an individual communication setting out the details and timing of the closure and their options for re-registration. Letters will be sent by PCSE on behalf of the local ICB.
- Remote registration/self-selected registration | This will be managed through GP2GP electronic transfer in most patients and patients can search online at Find a GP.
- Allocation | At the end of the remote registration/self-selection period, the remaining patients will be allocated to new practices. In cases of no response or no registration at another practice following the second reminder, patients must be allocated to a GP practice, except where they have not consulted or received treatment for 5 years or more, as confirmed by the GP practice.
- Transfer of records | Individual record transfers, triggered at re-registration, are done primarily electronically using GP2GP as per the current routine. Bulk transfers will be a managed process undertaken by the local commissioning support unit in conjunction with the clinical system providers. Some elements of records and supporting documents may still be transferred manually as per standard processes. It is imperative that at the end of the process all patient records and any associated data about patients, including electronic records, and any clinical correspondence are transferred to the provider with whom the patient has registered.
- Identification of vulnerable patients | For patient safety reasons the outgoing practice should notify the incoming practice of any potentially vulnerable patients.
Where a practice closes with no details of transfer, patients must be sent a letter informing them to register at another practice of their choice. As above, a proportion of patients will choose to re-register elsewhere, but some will not register elsewhere in the timescale given. The commissioner should ensure that the dispersal of all registered patients from the closed practice should be completed immediately following the contract end date, and within six months at the very latest, including reconciling any patients who have chosen not to re-register, ghost patients, etc.
Key considerations for patient list dispersal
Key considerations in patient list dispersal include:
- engagement with the NHS England (NHSE) regional team who will be needed to advise on details and confirm processes/instructions
- on average, it can take 1-3 months to clear patients from the practice list on the system, depending on list size
- practice list closures must be completed within any quarterly period, and within a financial year.
GP practice merger
A merger is where two or more practices join forces to form an enlarged single practice. It is important when practices are considering a merger to discuss IT requirements with the local support team at an early stage. Approval will need to be granted by the ICB.
Consideration needs to be given to existing IT infrastructure for example, server capacity and location, and as to whether the practices use the same clinical system. Migrating to a different clinical system will take time to plan, organise and complete (see link above to NHS digital clinical system migration guide). Even where both practices use the same clinical system it is likely that there will be differences in the way each practice uses it.
Key considerations for clinical systems when merging
Key considerations for clinical systems when practices are merging include:
- ensuring IT systems are aligned and if the IT systems at each practice differ, they will be required to be joined under one single provider
- planning and mitigating against minimal disruption by considering all online systems and emails
- ensuring practice policies and procedures are aligned – variation will always be found between practices clinical procedures and policies and a merger gives the opportunity to review and share best practice
- training needs of both clinical and non-clinical staff must be planned for – the actual process of data migration will itself make demands on practice resources
- ensuring decisions about configuration are made ahead of the migration date and importantly at a pace and timeline appropriate for the practice staff
- although the introduction of SNOMED CT has helped reduce clinical system configuration variations, aligning different practices’ clinical systems can be both a complex and sensitive exercise
- ensuring mirror images of each practice’s clinical system are in place by the time of the merger to minimise disruption to staff and patients
- ensuring all relevant, organisations, i.e. local hospitals, community trusts, pharmacies, and local authorities, are informed of the merger to make sure test results and any correspondence is sent to the correct email address
- ensuring third-party software licences are backed up
- ensuring all data protection issues are addressed prior to migration.
GP practice change of clinical system
The deployment of electronic health records began in 2000, with most practices having electronic systems by 2002. There was a wide variety of clinical systems in use initially, however as time has passed, provider numbers have reduced, and practices routinely choose the same clinical system across a local area.
Practices having different clinical systems has caused interoperability issues in the past. With the adoption of GPIT Futures and interoperability standards there have been improvements.
Migrations can take on average 12 -16 weeks from the point of order to go-live, and the managed change will be handled by the local commissioning support unit and the IT system supplier. The impact on a practice should not be underestimated.
NHS Digital’s clinical system migration guide gives an overview of the process and the planning and effort involved.
Performing a migration involves access to, and processing of personal patient data. The practice remains the data controller and adherence to the laws, policies, standards and guidelines relating to information governance is crucial. Details of the regulations involved are in the migration guide above.
In any system changeover there is a period when one system is shut down and all recording of patient information needs to be done manually until the record migration is complete (in most cases the records are transferred within two days). The manually recorded information will need to be entered into the new system to ensure patient safety and record completeness.
Migrations often run smoothly however issues can occur. NHS Digital notes potential issues to look out for such as coded data degraded to free text and missing attachments.
Risk in practice closures/mergers
The risks associated with practice closure/merger include:
- Patients who do not re-register when requested | There may be several reasons for this scenario, e.g. patients may have moved without notifying the practice and/or choosing another provider, patients may no longer live within the practice area or the UK, or patients may have passed away. If there is no response to PCSE letters an FP69 flag will be raised on the patient record and PCSE will follow the patient removals In this scenario practices need to print the record and return it to PCSE for storage.
In the event of a closure, the commissioner must be clear on the dispersal process they follow to avoid the risk of challenge from other local providers. Most patients will be distributed to a practice. If a patient has not been seen by a clinician or received treatment in primary care for 5 years or more, their records will be stored centrally until they register with a practice in the future, or the retention period is complete.
- Overburdening a receiving practice | Where staff shortages are affecting both individuals’ and practices’ workload it is imperative that the risk to receiving practices is taken into consideration. The increase in list size will of course mean extra income, but will bring with that extra demand, meaning capacity may well be an issue. Staffing, IT, premises, patient satisfaction and clinical safety all need to be considered when accepting a bulk increase in a practice list.
- Security and confidentiality | It is critical that the management and transfer of patient records (both paper and electronic) is undertaken in a secure and robust manner. It is important that information governance, records management, data protection regulations, and data protection principles are followed throughout this process.
Suppliers are committed to resolving any issues that might occur during a migration under the ‘overarching standards’ on the GPIT Futures framework. For a supplier to provide a clinical solution in the framework, they must meet the required conditions.
For clinical system migrations this is addressed in the following standards:
These are essential for suppliers to fulfil when migrating GP practices’ clinical systems (also known as the ‘foundation solution’).
The migration of patient records, for whatever reason, needs careful planning and management to ensure patient safety is paramount. There are a number of ongoing issues that need to be addressed to mitigate against future problems, including:
- the successful digitisation of Lloyd George records
- management of deducted patient records
- the seamless transfer of patient data between different clinical systems without degradation.
Related GPG content
- GP2GP – transferred in records – processing
- Information governance and data protection
- Keeping GP records
- Clinical coding – SNOMED CT
- GP contract
- Digitisation of Lloyd George records
Other helpful resources
- Primary Care Support England, Practice mergers & closures
- UK, GP registrations data (gp-registrations-data.nhs.uk) GP2GP patient record transfers data
- NHS England, 2022/23 Directed enhanced service
- NHS Digital, Records and document management policy
- NHS Digital, General Data Protection Regulation (GDPR)
- NHS England, Primary medical care policy and guidance manual (PGM)
- Professional Record Standards Body (PRSB), About us