There's been such a lot going on in the world of NHS data. It's taken me quite a few naptimes to read and cogitate on it all. Its 934 pages worth.....

We've obviously recently had the 10 year plan but also the life sciences sector plan, the data use and access act and the blueprint for modern digital government. Each of which has it's own lens on the buffet which is NHS data.

The new kids on the block (NKOTB)

1. 10-Year Health Plan (“Fit for the Future”) – a new overarching direction Our friends the 3 shifts (hospital→community; analogue→digital; sickness→prevention). It resets the frame for data/AI as a core enabler across the service and places the Single Patient Record in the middle of it. (no mention of data quality)
2. NHS Planning Guidance 2025/26 – upgrades the mandate to “FDP-first” (explicit connection of local data infrastructure to the Federated Data Platform; 85% secondary care adoption by Mar-2026). This is a harder steer than 2024/25. (no mention of data quality)
3. Data (Use and Access) Act 2025 (DUAA) – the new legal backbone for public-sector and commercial data use (verification services, Smart Data schemes, changes to DP/privacy law). Sets the cross-government data environment that DHSC/NHSE must operate within. Explicit about requirements for vendors on interoperability (hooray!). (no mention of data quality) - I know you get where I'm going with this but I'm trying this out like a Stuart Lee gag, if I keep going enough it'll get funny again.
4. Life Sciences Sector Plan (LSSP) – creates a Health Data Research Service (HDRS) with substantial investment, plus major commitments into Genomics England, Our Future Health and UK Biobank. This is the research/innovation pillar that depends on NHS data. (no mention of data quality)
5. CDDO’s “Blueprint for Modern Digital Government” – resets cross-government digital/data direction (with a new Government Digital & AI Roadmap). While not health-only, it exerts standards/assurance pressure on DHSC/NHSE. (no mention of data quality)

I've summarised my view of whats new, what builds upon previous policy and what contradicts previous or current policy.

The list of the many strategies

Core DHSC/NHSE strategies and delivery plans

1. Data Saves Lives (DHSC, 2022) – the umbrella health & social care data strategy. Still referenced as the baseline for later plans.
2. A Plan for Digital Health & Social Care (2022) – operationalises DSL (EPR coverage, records, standards).
3. NHS England Priorities & Operational Planning Guidance 2024/25 & 2025/26 – pushes NHS App, data-driven productivity, and an “FDP-first” approach.
4. Federated Data Platform (programme policy) – national usage policy, licensing, and rollout expectations.
5. NHS Community Health Services Data Plan 2024/25–2026/27 – sector-specific data standards, quality and timeliness fixes.
6. Fit for the Future: 10-Year Health Plan for England (2025) – positions data/AI/genomics as core to the new model of care.

Arm’s-length bodies / agency data strategies

7. UKHSA Data Strategy (2023) – quality, interoperability and research use of public-health data.
8. NHSBSA Data Strategy 2024–2029 – data platform/services underpinning national operations.
9. NHS.uk / NHS Digital product roadmaps with data duties (2025/26) – includes managing local services data and content accuracy.

Cross-government digital/data policy that binds DHSC/NHSE

10. Transforming for a Digital Future: Government’s 2022–25 Roadmap for Digital & Data – CDDO missions that departments (incl. DHSC) align to.
11. A Blueprint for Modern Digital Government (2025) – extends the cross-govt vision; explicitly references engagement with the NHS.
12. Data (Use and Access) Act / reform package (2025) – the national data-protection reform shaping public-sector data use and access.

Life sciences and innovation policies with NHS-data at the core

13. Life Sciences Sector Plan (2025) – creates a Health Data Research Service, and sets major data-driven R&D investments (Genomics England, Our Future Health, UK Biobank).
14. Life Sciences Industrial Strategy (2017) & update – legacy but still cited as the origin of the data/genomics plank.
15. Goldacre Review – Better, Broader, Safer (2022) – not a “strategy” per se, but adopted as policy direction on TREs, open methods and analytics; repeatedly referenced by DHSC/NHSE and bloody good work.

Links here.

Despite there being close to 1,000 pages, there's 10 key gaps across the policy landscape.

1. No dedicated NHS digital & data workforce strategy. Still.

NHSE confirmed it dropped the promised stand-alone plan; any digital workforce content will be folded into the LTWP refresh instead. That leaves no NHS-specific plan for DDaT roles (analysts, engineers, product, cyber) on pay, progression, supply, and training at provider/ICS level. Digital Health

Today, the cross-government DDaT Capability Framework exists, and NHSE is involved in its design council — but that’s not a substitute for a health-sector strategy tied to delivery. Especially with CSUs being dissolved. ddat-capability-framework.service.gov.uk
What good looks like: a published NHS DDaT plan with role profiles, pay bands, progression routes, training volumes (pre- and in-service), and ICS/provider workforce baselines, aligned to LTWP. NHS England

2. Skills to use what we’ve bought (EPRs, platforms)

Evidence shows many staff still struggle to use EPRs effectively; benefits are blunted by poor implementation and limited training. This is a capability gap, not just a kit gap. Financial Times
What good looks like: protected time + national curricula for super-users, minimum training standards in contracts, and benefit-realisation targets tied to utilisation and benefits cases achieved — not just deployment.

3. Two “front doors” for data access, one estate

FDP-first mandates operational connectivity (85% secondary care by Mar-2026). In parallel, the Health Data Research Service (HDRS) is being stood up as the single research gateway with ~£600m backing. Without a published operating model joining these up, organisations face duplication (pipes, IG, cost). NHS England
What good looks like: a single, public NHS Data Operating Model that explains routing (ops vs research), shared standards, IG artefacts, and who pays for what — showing how FDP and HDRS interlock. ukhealthdata.org

4. Information governance: law has moved; NHS playbook hasn’t (yet)

The Data (Use & Access) Act 2025 changes the legal backdrop and phases in through 2026, but there isn’t (yet) a consolidated NHS IG playbook that reconciles DUAA with health-specific requirements (confidentiality, SDE/TRE practice) and with local realities. Legislation.gov.uk+1
What good looks like: a refreshed NHS IG framework (templates, lawful bases, DPIA exemplars) mapping DUAA to health data routes (direct care / planning / research), including TRE/SDE patterns and citizen communications.

5. Adult social care integration: digitisation ≠ interoperability

DSCR uptake has risen, but targets slipped and remain incomplete; joining ASC records with NHS shared care records is still patchy and variable by ICS. National Audit Office (NAO) Care Quality Commission
What good looks like: a funded end-state architecture and standards pack (terminologies, event sets, minimum operational data) + milestones for bidirectional exchange between DSCRs and Shared Care Records. standards.nhs.uk

6. Community & mental health data quality still behind acute

NHSE’s Community Health Services Data Plan (2024–27) acknowledges the gap; MHSDS coverage is improving but data completeness/quality remain uneven. These sectors carry the load in the 10-Year Plan; their data can’t be second-class. NHS England
What good looks like: mandated core data sets with funding for extraction/validation, fewer bespoke returns, and transparent quality dashboards tied to payment or performance levers. NHS England Digital

7. AI in health: frameworks yes, strategy no

We have MHRA’s SaMD/AI programme and NICE’s evidence standards; what’s missing is a single NHS AI strategy that covers evaluation, assurance, procurement, monitoring, and decommissioning across care settings. GOV.UK

Independent analysis has called for a dedicated NHS AI strategy to end fragmentation. Health UK
What good looks like: one NHS AI playbook tying MHRA/NICE to commissioning and information standards (including post-market surveillance via FDP/SDEs).

8. Public trust & participation model (beyond slogans)

The Goldacre Review set expectations on TREs, open methods, and citizen engagement; HDRS stresses secure, single-gateway access — but the NHS-wide participation model (opt-outs, feedback, social licence) still lacks a simple, unified story. GOV.UK
What good looks like: a national participation framework (plain-English uses, controls, benefits-sharing) embedded into NHS App journeys and HDRS/FDP onboarding. Wellcome

9. Benefits & value tracking for the big platforms

The system has mandated platform adoption (FDP-first), but there’s no consistent, published benefits framework that tracks actual productivity, safety and pathway outcomes at trust/ICS level (separate from deployment KPIs). NHS England
What good looks like: a public benefits model with baselines, counterfactuals, and quarterly reporting (e.g., time-to-insight, prevented harm metrics, reduced duplicate tests), audited by NHSE regions.

10. Training & change funding (recurring, not one-off capex)

Reports keep finding that people-costs (time to train, redesign, data quality) are underfunded relative to tech spend. Without ring-fenced OPEX for adoption, benefits stall. Financial Times EPR usability survey
What good looks like: fixed ratios for training/change vs tech in business cases, and multi-year revenue funding linked to measurable adoption.

Do I want more policies to add to the pile? Not really, but we need them.

This fortnight I have been mostly....

In hospital with the baby, she decided that breathing was optional for a bit so we took a trip in an ambulance and spent a few days getting tested. Luckily all ok and shes back in good form. My back is lagging after sleeping on the pullout next to her cot.

Reading - Kate Tarling - The Service Organisation

Listening to Late Night Tales to remind myself of when I was fun.

Next issue is going to be on finance, payments and tariff.

TTFN