SCCI Development Framework

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SCCI Development Framework

Document filename: SCCI Development Framework

Directorate / Programme SCCI Project Development

Support Service

Document Reference <insert>

Project Manager [Manager] Status Approved Interim

Owner Gwen Smith Version 1.0

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Document Management

Revision History

Version Date Summary of Changes 0.1 13/08/2014 First Draft

0.2 08/10/2014 Second draft following limited review

0.3 16/10/2014 Final Draft for submission to SCCI following SMG review

1.0 24/11/2014 Accepted by SCCI as interim pending review following NIB Framework and Standards Chapter publication

Reviewers

This document must be reviewed by the following people: author to indicate reviewers

Reviewer name Title / Responsibility Date Version

SCCI Development Support Team Operational team 0.1

SCCI Service Management Group Operational management of SCCI services

0.2

SCCI membership Approvers of final draft 0.2

ISAS Independent Standards _{Appraisal Service} 0.2

Approved by

This document must be approved by the following people: author to indicate approvers

Name Signature Title Date Version

Standardisation Committee for Care Information

Standardisation Committee for Care

Information 29/10/2014 1.0

Glossary of Terms

The glossary is accurate at the time this document was published; for more up to date information use the links provided in section 6 Sources of Information.

Term /

Abbreviation

What is stands for

ALB Arm’s Length Bodies

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Term /

Abbreviation

BIS Department of Business, Innovation and Skills BPG Business Planning Group

Business Lead The Programme/Project Lead within an organisation who is directly responsible for delivery and maintenance of an ISCE; the business lead can be from any organisation and

occasionally will be within HSCIC Caldicott Guardian

CEO Chief Executive Officer

Collection Where information is collected and distributed to the centre or requesting body to conform to the information request, either specifically as a result of the data request, or as a by-product of another process (e.g. operational systems, data sets

Concordat An agreement between the partner organisation that constitute the membership of NIB to work collaboratively towards all ‘information and data’ flowing to HSCIC; either as primary or secondary flow

CQC Care Quality Commission

Developer The individual/s who is designated as the developer of an ISCE or a component part of it

DH Department of Health

Direction A direction to HSCIC as defined in section 254 of the Health and Social Care Act 2012

DTR Draft Technical Regulation DTU Draft for Trial Use

EC98/34 European Commission Technical Standards and Regulations Directive 98/34

EU European Union

Extraction Extraction is the term given to a customer request and refers to the act of obtaining information from general practice systems with the aim of improving patient care

FOMI False or Misleading Information HRA Health Research Authority HSCA 2012 Health and Social Care Act 2012

HSCIC Health and Social Care Information Centre IAP Impact Assessment Panel

I2N Idea to Need

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Term /

Abbreviation

Standard Care Act 2012

ISAS Independent Standards Assurance Service

ISB Information Standards Board for Health and Social Care ISCE Information Standards Collections (including Extractions) ISCEG Information Standards Collections and Extraction Group

(working name of SCCI)

ISCG Informatics Services Commissioning Group, former name of NIB

MHRA Medicines and Healthcare Products Regulatory Agency Major A categorisation of a change submission which is defined by a

set criteria as laid out in the change categorisation tool Mandatory

Request

A request to HSCIC to collect data which is mandatory as defined in section 255 of the Health and Social Care Act 2012 Minor A categorisation of a change submission which is defined by a

set criteria as laid out in the change categorisation tool

Monitor As the sector regulator for health services in England, Monitor’s job is to make the health sector work better for patients.

N2R Need to Requirement

NHS National Health Service NHS

Confederation

The NHS Confederation is the membership body for all organisations that commission and provide NHS services NHS DD NHS Data Model and Dictionary

NIB National Information Board

NICE National Institute for Health and Care Excellence NTPS National Tariff Payment System (new name for PbR)

PbR Payment by Results

PfC Proposal for Change PHE Public Health England

PRSB Professional Record Standards Body Project/Programme

Lead

The role of the Project/Programme Lead is to support the SRO in their work with the developer organisation and is referred to as Business Lead throughout this document.

Request A request to HSCIC to collect data which is not mandatory as defined in section 255 of the Health and Social Care Act 2012 ROCR Review of Central Returns replaced by the Burden Advice and

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Term /

Abbreviation

SCCI Standardisation Committee for Care Information

SCCI Front Door The terminology used where all ideas are submitted to, also known as Idea to Need (I2N)

SME Subject Matter Expert

SoN Statement of Need

SoS Secretary of State

Sponsor The Sponsor is the individual that takes on responsibility for an ISCE including funding

SRO Senior Responsible Owner

Submitter The individual or organisation who has proposed an idea or a request for change to an existing ISCE

Survey A collection of data in the form of a request for answers to questions designed to gather information to support programmes of work and health and care initiatives

techUK techUK provides a collective voice for its members and drives connections with government and business to create a

commercial environment

SPNS Single Publication and Notification Service

‘Within Tolerance’ A ISCE change pathway. The pathway is used where a change can be identified as being within the defined tolerance levels that do not require a change to the approved ISCE. The tolerance levels must be defined within a maintenance plan which was approved as part of the ISCE.

Document Control:

The controlled copy of this document is maintained in the HSCIC corporate network. Any copies of this document held outside of that area, in whatever format (e.g. paper, email attachment), are considered to have passed out of control and should be checked for currency and validity.

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Contents

1

Introduction

8

1.1 Purpose of Document 8 1.2 Background 8 1.3 Document Scope 9 1.4 Audience 9

2

SCCI Support Services

10

3

Process Overview

12

3.1 Process Scope 12

3.2 High Level Process 12

3.3 Review process 19

3.4 Impact Assessment and Prioritisation 20

3.5 Collections 21

3.6 Publishing 29

3.7 Roles & Responsibilities 30

3.8 Workload management 34 3.9 Issue resolution 36

4

Stages

37

4.1 Idea to Need 37 4.2 Need to Requirement 39 4.3 Requirement to Draft 42 4.4 Draft to Full 44 4.5 Review 46 4.6 Retire 49

5

Product Descriptions

51

5.1 Product Pathway Matrix 52

5.2 Product Descriptions 55

6

Sources of Information

59

Appendix A.

SCCI Support Services

60

7.1 Structure 60

7.2 Scope 60

7.3 Idea Development 60

7.4 Development Support 62

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7.6 Publication and Knowledge Management Service 68

7.7 Secretariat 70

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1 Introduction

1.1 Purpose of Document

This document defines the Development Framework for Information Standards and

Collections including Extractions (ISCE) to support the Standardisation Committee for Care Information (SCCI). It is intended to provide help and guidance to anyone wishing to submit ideas or changes into the process to obtain approval to publish as a Standard as described within the Health and Social Care Act 2012

(http://www.legislation.gov.uk/ukpga/2012/7/contents/enacted) or publication as an assessed and accepted collection. Additionally it provides an overall framework within which the Health and Social Care Information Centre (HSCIC) teams who support the SCCI operate.

The aim is to provide a framework that:

 encourages the development of efficient and justified improvements in the information needed for Health and Care delivery,

 enables understanding how the system supports individuals

 enables understanding of how the system is performing at national level

 enables services which are focussed on supporting the submitter, developer and business leads.

1.2 Background

The SCCI Lifecycle has been described in “The ISCE Process” and is depicted as a ‘Tube Map’ which is recreated in Figure 1. Note that the tube map describes a development lifecycle and is not intended to detail a process.

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EU decide to legislate Member state detailed opinion Consider detailed opinion

Deprecate

S Initial Idea Received

Draft a proposal Design Build 0 Need accepted Initial test Implementation test Notify BIS

BIS notify EU and member states

E Retire Redesign Requirement elaborated 1 Requirement accepted Live deployment Benefits realisation

Initiate Routine maintenance Consultation

Appraisal and assurance service Development and maintenance Implementation and benefits realisation EU Directive 98/34 3 Technical Regulation Published 2 Draft Technical Regulation Released

Education & Training Support

4 Review

Systemic Adoption

Applies to s.250 & 259 standards only

Title: Standards & Collections Lifecycle

Status: Draft

Version: 0.6

Date: 10th_{September 2013} Design Accepted

Retirement

Figure 1 Information Standard and Collection life and assurance cycles

To support this lifecycle a number of services have been established; each service operates within the boundaries of this framework and their defined processes and procedures.

1.3 Document Scope

This document provides a high level description of the activities and processes to support SCCI acceptance and approval; it does not provide granular detail of individual processes and procedures, this detailed information can be found by following the links in section 6

Sources of Information. The document specifically provides guidance in relation to submissions listed as being in scope.

1.4 Audience

The audience of this document is:

 Submitters of ‘ideas’

 Developers of Information Standards, Collections and Extractions

 SCCI Support Teams members

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2 SCCI Support Services

A number of services have been established to support SCCI and the development,

assurance, approval and publication of ISCE as they flow through the system. The support services include teams which have specific focus on the following areas:

 Idea Development - Provides a ‘front door’ for ISCE ideas for improvement. A

nominated member of the team will work with the submitter of an idea to introduce a new ISCE or change an existing one, to establish and document the national need. This short step includes, obtaining relevant HSCIC subject matter expert (SME) input to ensure that consideration is given to existing standards and resource impacts.

 Development Support – Provides an overall planning, management help and advice service for anyone submitting (or intending to submit) an ISCE. The team will work with the submitter the business lead and other SCCI services to support them in achieving the best outcome. The team will engage with other services across HSCIC and the Health and Social Care system as required to ensure progression of the ISCE through the process where possible, including looking at impact on existing ISCE. The team additionally provides management reporting and information across the whole process.

 Independent Standards Appraisal Service (ISAS) – Provides an independent critical appraisal service to support SCCI in their decision making. The team will liaise with Development Support to appraise and assure submissions before they are passed to SCCI. The team will manage the appraisal process undertaken by independent external appraisers and prepare a recommendation report which will be submitted alongside other documentation to SCCI. To ensure the objectivity appraisers are independent of development.

 Publication and Knowledge Management – Provides a publication and knowledge management service. The team will work with NHS England, HSCIC Board and others to obtain appropriate approval letters and ensure the publication of Information Standards Notices. The team additionally provides a knowledge management and consultation service across SCCI support services and to submitters.

 Secretariat - Provides the management and organisation of SCCI meetings including the recording and notification of discussions and decisions. This service is currently hosted by NHS England

 Burden Advice and Assessment Service (BAAS) – Provides advice on the burden across Health and Care of all submissions and produces burden assessment reports. Requests for burden assessment and advice would normally come through the single SCCI ‘front door’; the team however, has additional responsibilities outside the SCCI process; it is not a SCCI only service although the team provides input on all

submissions.

Full details of the SCCI Support Services are provided in Appendix A.

In addition to the dedicated SCCI Support Services a number of other teams within the HSCIC will have to be engaged through the process for example to ensure that the proposal is compliant with other standards. These additional services need to be engaged dependant on the nature of the submission; examples are given below but it is not an exhaustive list:

 Technical Architecture Team

 NHS Data Dictionary Team

 Clinical or Pharmacy Terminology Team

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3 Process Overview

3.1 Process Scope

The SCCI development process provides a mechanism to progress ISCE at various stages of their development and from any source, including initial ideas. It is assumed that not all submissions into the process will be fully worked up and resources to progress may not be in place as an idea is submitted. The process starts when an ‘idea’ is submitted and ends when the ‘idea’ is published as an approved ISCE under the Health and Social Care Act 2012. Submissions will broadly fall into one of the following categories:

 Information standard idea:- a business requirement for an information standard

 Collection / Extraction idea:- a business requirement for a national or cross organisation collection or extraction of data

 Information standards change:- a business requirement and or proposal to change an approved ISB or SCCI standard

 Collection / Extraction change:- a business requirement to change an approved ISB, ROCR or SCCI Collection / Extraction

Please note this is not an exhaustive list and other types of submissions may be accepted. Should you require information or advice please contact the Development Support team via email ([email protected])

3.2 High Level Process

The process is split into a number of logical stages:

 Idea to Need – develop an ‘idea’ into a justified need for consideration by SCCI.

 Need to Requirement – develop an accepted ‘idea’ and document the individual unique requirements which will meet the need.

 Requirement to Draft – design a solution which meets the requirements and

considers existing standards; build the solution and test that it can be implemented; plan consultation, implementation, how it will be maintained and understand the benefits.

 Draft to Full – undertake European consultation if appropriate; understand the results of the consultation and adjust the solution and implementation plans as needed. First of type implementation could also be undertaken within this stage. Generally first of type (if appropriate) will be performed in requirement to draft.

 Benefits Realisation Review – after implementation gather feedback from the implementation; understand any changes which may be required and the benefits which have been realised.

 Retire – understand the reasons to retire, consult and plan retirement.

New ISCE which have not previously been through the process (or approved under the old Information Standards Board for Health and Social Care or ROCR regime) would be

expected to follow the full process and pass through each of the logical stages. The process provides consistent quality assurance and ensures that appropriate consideration is given to alignment with other standards; legal and confidentiality obligations in respect of the ISCE and implementation. Stages may be combined where it is appropriate: this could be in order to meet implementation deadlines or where the tasks and documentation is largely

completed when submitted. Combining stages provides less opportunity for progress and documentation to be assured and to receive feedback from SCCI; this in turn increases the risk of not meeting the expectations of SCCI and requiring rework. A wish to move rapidly

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through the process must be balanced with the risk of doing so without formal assurance of work being undertaken.

Combining stages would only be recommended where the risk is low and is accepted by the Senior Responsible Owner (SRO). The developing team must also have the capacity to complete all tasks within a potentially shortened timeframe.

3.2.1 Full process activities

New ISCE or changes which are major and impact other standards will normally be expected to proceed through each stage in turn. The figure below provides a simple view of activities which are undertaken within each stage and the progression through stages.

Retire

Consult Plan retirement

Communicate deprecation / retirement plan Publication Review Post implementation report benefits realisation

analysis Change analysis

Change documentation and implementation Draft to Full European Consultation (only if required) identify and undertake any re work ISAS (10 working days)Appraisal SCCI presentation / accepted as full standard Publication Requirement to draft Requirement Elaborated design solution, consult and test plan implementatio n ISAS Appraisal (10 working days) SCCI presentation / accepted as draft standard Publication Need to Requirement Readiness/ impact/priority Assessment burden assessment Requirement documented ISAS Appraisal (10 working days) SCCI presentation / Requirement accepted Idea to Need

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Figure 2 – Stage Activity overview

Figure 2 above provides a high level overview of the full end to end lifecycle activities. Actual time taken to complete the stage is dependent on the capacity of the business to complete the tasks and may be longer than those shown above in some instances. Dependency on things outside the SCCI process may additionally cause delays e.g. ministerial decision. More detail of each of the stages is provided in the section below Stages.

At the end of each stage a presentation of documentary evidence is made to SCCI who will provide confirmation that the submission remains ‘on track’ and is acceptable to progress to the next stage with any caveats. With the exception of ‘Idea to Need’, all documentary evidence undergoes appraisal by the ISAS in advance of being presented to SCCI. ISAS provides additional advice to SCCI in the form of a recommendation report. The

recommendation report will be considered by SCCI alongside all other documentary evidence; SCCI will determine the outcome based on evidence presented.

The stages above, with the exception of Idea to Need, may be combined in some instances where this is appropriate. Combining stages will be considered in conjunction with the SRO where there is confidence that documentary evidence; testing and communication

requirements for multiple stages can be met without risk to the quality of the standard, public safety and or burden across the Health and Care system. The scope and scale of the

submission will also be considered; combining stages will normally be agreed as an

exception where there is strong justification and need to shorten the overall time to approval. It should be noted that where stages are combined, all evidence for each stage will be

appraised and presented to SCCI at one meeting; by agreeing to a combined stage submission the SRO is accepting the risk that work on a subsequent stage is undertaken without knowledge or feedback from SCCI. This may lead to a greater level of rework being needed and risks unforeseen delays in progress to full approval.

3.2.2 Change Categorisation

Change categorisation takes place alongside prioritisation and impact assessment and is undertaken by the Impact Assessment Panel (IAP). A link to additional information about IAP and its terms of reference can be found in section 6 Sources of Information. Changes are categorised by using the change categorisation tool; Appendix B.

Categorisation takes account of:

 any outstanding conditions set at previous approval

 fitness for purpose of the ISCE following the specified change

 scale of change

 is it a change or a correction

 any agreed maintenance plan and if the change is within tolerance of the plan

 the impact of the identified change in the following areas

o scale of burden cost either in currency or days effort

o information governance

o implementation timelines / impact on suppliers

o impact on other existing standards

3.2.2.1 Change Categorisation Criteria

The Change pathways are described in section 3.2.3 below. To be categorised as a particular type of change the following criteria must be true.

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 Changes that do not fit into any of the categories below will be subject to the full process due to their scope, complexity and impact.

 Changes that require EU consultation will have an additional submission to SCCI to enable the review of any feedback received.

Data Dictionary Change Notice:

 A change to the Data Dictionary

 No impact on an existing ISCE or systems across Health and Care

 It is a cosmetic change to the Data Dictionary only

Corrigendum:

 A correction to publication documents for an ISCE.

 No impact on burden,

 No impact on benefits

 No impact on other ISCE

 No impact on implementation. This could include publication of a correction before implementation that may impact implementation if it were published later

Within Tolerance:

 A change which falls within the scope of what has been defined and approved by SCCI as part of a ‘business as usual’ maintenance plan when originally submitted and approved

Minor Single Submission:

 Not a DDCN, Corrigendum or within Tolerance change

 Burden impact less than £70,000 across the Health and Care system

 Burden effort less than 1 year across the Health and Social care system

 No Information Governance Issues or any governance issues have been resolved

 No impact on implementation timelines where the ISCE has not yet been implemented

 Effort to implement all required changes to a system less than six months

Major Single Submission:

 Not a Minor change

 Fails two or less of the following criteria:

o Burden impact less than £70,000 across the Health and Care system

o Burden effort less than 1 year across the Health and Social Care system

o No Information Governance Issues or any governance issues have been resolved

o No impact on implementation timelines where the ISCE has not yet been implemented

o Effort to implement all required changes to a system less than six months

Major Two Stage Submission:

 Not a Minor or Major Single Stage change

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 Fails two or less of the following criteria:

o Burden impact less than £70,000 across the Health and Care system

o Burden effort less than 1 year across the Health and Social Care system

o No Information Governance Issues or any governance issues have been resolved

o No impact on implementation timelines where the ISCE has not yet been implemented

o Effort to implement all required changes to a system less than six months

3.2.3 Change Pathway activities

Changes will normally follow a process which integrates stages dependent on the scale, scope and burden of the change. This enables minor or major single stage (due to low risk) category of changes to be accepted through a ‘fast track’ method. There are 5 basic paths which are determined based on the category of change:

 Major Two Stage submission – categorised as a major change but able to be compressed into 2 stages. Will be reviewed by SCCI as a requirement and as a full standard.

 Major One Stage submission – categorised as a major change but the risk and scope of the change is small enough to enable it to be compressed into a single stage. Will be presented to SCCI for acceptance to publish as a full standard

 Minor One Stage submission – categorised as a minor change which is low risk, scope and burden. Will be presented to SCCI for information and acceptance to publish as a full standard.

 Corrigendum – categorised as being the correction of an error in a published standard. The correction must have no material impact on the standard or its

implementation. Will be presented to SCCI for information and acceptance to publish the corrigendum.

 Data Dictionary Change Notice – not strictly a change to a standard but will follow the same categorisation process to establish that there are no impacts to any standards. Will be presented to SCCI for information only.

 Within Tolerance Change – categorised as a change that is within tolerance of an approved maintenance plan. Will be presented to SCCI for information only. Major 2 stage submission:

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Figure 3 Major 2 stage submission activities Change single stage submission:

I to Need (0

working days)

Figure 4 Minor & single stage major change submission activities Corrigendum submission:

:

Full

Design solution, consult and test

ISAS appraisal (10 working days)

SCCI presentation and

acceptence Publication

Requirement

Elaborate proposal for Change

Document

Requirement Plan implementation

SCCI presentation and acceptence

Change process Impact assessment, categorisation and prioritisation

Impact assessment &

categorisation Burden Assessment Prioritisation Determine Path

Idea to Need (0 working days)

Logged and passed to Change process

Full Elaborate proposal for Change Document Requirement Plan implementation Design solution, consult and test

ISAS appraisal (10 working days) SCCI presentation for information and acceptence to publish Publication Change process Impact assessment, categorisation and prioritisation

Impact assessment &

categorisation Burden Assessment Prioritisation Determine Path Idea to Need (0 working days)

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Figure 5 Corrigendum Activities Data Dictionary Change Notice:

Figure 6 Data Dictionary Change Notice

Data Dictionary Change

Document Data Dictionary Change Notice

ISAS appraisal (4 working

days) Publication

SCCI presentation for information Change process Impact assessment, categorisation and prioritisation (15 working days)

Impact assessment & categorisation Prioritisation Determine Path Corrigendum Document Corrigendum Produce Corrigendum publication documents ISAS appraisal (5 working days)

SCCI presentation for information and acceptence to publish

Publication Change process Impact assessment, categorisation and prioritisation (15 working days)

Impact assessment &

categorisation Burden Assessment Prioritisation Determine Path Idea to Need (0 working days)

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Figures 3, 4, 5 and 6 above provide a high level overview of the change process activities for changes to ISCE. Actual time taken to complete the stage is dependent on the capacity of the developer to complete the tasks and may be longer than those shown above in some instances. Dependency on things outside the SCCI process may additionally cause delays e.g. ministerial decision. Please note that if EU consultation is necessary then an additional 120 working days will be required to complete the EU consultation process; it is not expected that Data Dictionary Change Notice will require EU consultation..

3.3 Review process

As part of acceptance a benefits realisation review date for any ISCE is agreed by SCCI; to enable the committee to understand how well it has been implemented and if the expected outcome has been achieved. This review of an approved ISCE is considered in addition to the three year review of all approved collections which is undertaken by the BAAS team. An ISCE review will be aligned with the three year review where it coincides with it. As the review date is approaching the business lead responsible for maintenance will be contacted by the Development Support Service to start the process.

3.3.1 Purpose

The purpose of the review is to understand:

 How successful was implementation?

 Are benefits being realised?

 What has been achieved since acceptance?

 Is the standard still relevant and fit for purpose?

 Is the standard meeting its specific need/requirement?

 Are there any changes needed as a result of lessons learned from implementation? It should be noted that following the implementation of the SCCI process in April 2014,the first review of standards which were approved under the old Information Standards Board (ISB) regime will additionally look to understand:

 What additional work is required to uplift the standard to comply with the Health and Social Care Act 2012?

 Can this work be undertaken as part of the review; or agree the timescales for uplift?

3.3.2 Review process scope

The scope of the review process is all ISCE which have been accepted by SCCI or its predecessor the ISB.

3.3.3 Overview

The review process is split into two potential stages:

 Standard Review – review implementation; understand any benefits and any changes which may be necessary.

 Standard Uplift – review work necessary to uplift to a Health and Social Care Act published standard, plan and potentially undertake the uplift (only for first review of standards approved by ISB).

Please note that the review will be presented to SCCI at each stage.

3.3.4 Review Pathway activities

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Idea to Need (0 working days)

Figure 7 SCCI review process activities

Figure 7 above provides a high level overview of the activities of the review process. The standard uplift process is optional (it will only be completed where an ISCE needs to be uplifted to become ACT compliant; where uplift is needed then the review of work required to uplift will be undertaken within the timescales of the standard review. The work required and plan for uplift will be presented to SCCI at the standard review stage. In exceptional

circumstances where the uplift is possible within the standard review timeframe the uplifted documentation will also be presented at the standard review stage.

3.4 Impact Assessment and Prioritisation

Impact Assessment and Prioritisation is conducted by the IAP and takes place either following an idea or change being submitted. The assessment takes place alongside the change categorisation process (changes only), collection categorisation process (collections only) and subject matter expert input request for new ideas; the following outputs are

produced:

 A prioritisation score which can be used to compare relative priorities of work

 A change categorisation as described in section 3.2.2.1 (changes only)

 A collection categorisation as described in section 3.5.3 (collections only)

 An IAP outcome which will be in the form of a categorisation, a statement from each panel member and a general statement from the IAP as follows:

o support the work in its current proposed form, no caveats

o support the work in its current proposed form, caveats and delivery

recommendations applied (e.g. wider engagement and interdependencies to be addressed)

Optional Standard uplift

review work needed to uplift Document necessary changes Uplift documentation ISAS appraisal (10 working days) SCCI presentation for acceptence to publish Publication Standard Review Review imlementatio n Review burden / benefits / achievement s Review relevance / fitness for purpose Plan and document changes Plan any uplift (optional) ISAS appraisal (10 working days) SCCI presentation for acceptance Publication Review activation (6 months in advance of SCCI presentation)

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o panel statement: support the work; caveats to one or more areas, conditions and risks being added to the risk register

o any Impacts and Risks

Note: IAP does not reject, but they may provide advice that the SRO and business lead reconsider their submission in line with caveats and recommendations of the panel; they additionally may request advice from SCCI in exceptional circumstances

Prioritisation and impact assessment takes account of:

 Impact

o Inter-dependencies

o strategic considerations

o risks – including but not limited to: reputational damage and visibility

o caveats

o burden

o Clinical safety

o information governance

o technology and architecture

o compliance to existing standards

 Expected benefits

o to individuals

o to care providers

o to service management

 Ease of delivery in respect of

o funding

o resource

o technical

o commercial

o appetite within the health and care system

o business change

o business leadership

The IAP outcome is updated throughout the process and is part of any submission to SCCI.

3.4.1 Prioritisation report

Prioritisation scores will be recorded within a report for publication and presentation to SCCI each month which provides a relative comparison of all active items in the SCCI process. This will inform any decisions SCCI are required to make in respect of prioritising one submission over another when scheduling conflicts occur.

3.5 Collections

All national collections are in scope of SCCI regardless of whether they are part of Information Standards. Local collections are not in scope unless they are for national implementation. The need for collections can happen quickly and it may not be practical to take them through the full SCCI process; an amended process will be applied to submissions for collections. There are a number of different categories of collection in scope of the SCCI process. Each category has different levels of impact and risk across the health and social care system; it is the level of impact and risk which is used to determine the path that a request will take, this in turn dictates the level of scrutiny and assurance required to gain SCCI acceptance. The broad categories (which are not mutually exclusive) are described below:

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 A mandatory national collection which is not part of an information standard.

 A voluntary ongoing collection which is part of an information standard.

 A voluntary ongoing collection which is not part of an information standard.

 A voluntary ‘one-off’ collection which is not part of an information standard.

 A ‘one-off’ survey (please note this will be treated in the same way as a collection).

 A recurring survey (please note this will be treated in the same way as a collection) The terms ‘collection’ and ‘information standard’ is used within the context of the definitions provided within the glossary

Details of all collections approved through the SCCI process are currently published on the Burden Advice and Assessment Service website. [DN – add link to BAAS published

collections]

3.5.1 Impact and Risk Assessment

In order to determine the category of a collection and therefore its development pathway, an impact and risk assessment is undertaken managed by the SCCI support services. This assessment takes into account:

 Frequency of collection – is it one-off or a regular collection

 Burden of collection – what is the cost to the service of collection in terms of financial and time effort. The scale and coverage of the collection is considered as part of the burden assessment. Please note that the full methodology for burden assessment is published here.[DN link to burden methodology to be added]

 Information Governance implications – does the data being collected create

information governance issues and / or pose a risk to patients, public or the collecting organisation which have not been resolved. Does the collection include patient

identifiable or confidential information and how will this be addressed to ensure confidentiality remains secure?

 Is the same data being collected elsewhere or within a previous collection?

 Previous submission where it is a re-submission of a one-off collection

 Legal basis for the flow of information (if required).

 Voluntary or mandatory nature of the collection.

 Any requirement for EU consultation.

 Impact on existing standards or collections.

 Compliance to existing ISCE.

The impact and risk assessment decision will be in the form of a collection summary report stating an agreed pathway and may include some conditions to be met as part of

acceptance. This decision will be documented and the IAP Secretariat will send a formal notification to the submitter.

3.5.2 Collection pathway activities

Collections will generally follow a process which combines stages and potentially reduces the documentation requirement dependent on the risk and impact assessment. This enables small low risk and low burden collections to be accepted through a ‘fast track’ method where it is not appropriate or practical to bring such collections through the full SCCI process. There are 4 basic pathways which are determined based on the level of impact and risk:

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 Light impact – categorised as low impact, low burden and low risk collections. Will follow a ‘light touch’ process; will be presented to SCCI for information and

acceptance

 Low impact – categorised as low burden, low or medium impact but medium risk. Will follow a ‘light touch’ process; will be presented to SCCI for acceptance.

 Medium impact – categorised as up to medium impact and burden but high risk. Will follow a single stage submission process; will be assured by ISAS with a reduced documentation requirement and presented to SCCI for acceptance.

 High impact – categorised as high impact and burden and high risk. Will follow a two stage submission process; both stages will be assured by ISAS with a reduced documentation requirement appropriate to collections and presented to SCCI for acceptance.

Light and Low collections may be accepted by SCCI through Chairs action outside of a formal meeting where it is urgent.

Light impact

Figure 8 - Light impact collection activities

Figure 8 above provides a high level overview of the light impact activities; timings provided are estimated and may vary. Activities within the light impact pathway will run in parallel and assuming that required documents are received it is expected not to take longer than 7 weeks to gain approval.

Low impact Light impact Burden assessment consultation Burden assessment report Produce Collection Summary report SCCI SMB verification SCCI presentation for information and acceptance to publish Publication Collection process Impact assessment, categorisation and prioritisation

Impact assessment & categorisation Prioritisation Determine Path Idea to Need (0 working days)

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Figure 9 – Low impact collection activities

Figure 8 above provides a high level overview of the low impact activities; timings provided are estimated and may vary. Activities within the low impact pathway will run in parallel; in this instance however submission to SCCI is required to gain approval and it is not expected to take longer than 11 weeks.

Medium impact Low impact Burden assessment consultation Burden assessment report Produce Collection Summary report SCCI SMB verification SCCI presentation

for acceptence Publication Collection process Impact assessment, categorisation and prioritisation (15 working days)

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Figure 10 – Medium impact activities

Figure 10 above provides a high level overview of the medium impact activities; timings provided are estimated and may vary dependent on available resource to complete work required. Activities within the medium impact pathway will run in parallel; in this instance however ISAS appraisal followed by submission to SCCI is required to gain approval and it is expected not to take longer than 18 weeks.

High impact Medium impact Burden assessment consultation Burden assessment report Produce Collection Summary report Produce specification Produce implementati on guidance ISAS appraisal (10 working days) SCCI presentation for acceptance Publication Collection process Impact assessment, categorisation and prioritisation (15 working days)

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Figure 11 High impact collection activities

Figure 11 above provides a high level overview of the high impact activities; timings provided are estimated and may vary dependent on available resource to complete work required. Activities within the high impact pathway will run in parallel where this is possible; in this instance however submission to ISAS and SCCI for acceptance is required at two stages. The first submission is to gain acceptance of the requirement before completion of the specification and implementation guidance and submission for full approval. It is expected not to take longer than 18 weeks.

3.5.3 Collection Categorisation criteria

To be determined to be within a particular category all criteria as defined below must be met; if one or more criteria is not met it will be tested against the next level up until categorised as high impact. All changes to existing collections will be categorised to ensure that the

category is unaffected by the change.

Light impact:

One-off or voluntary collection (without the need for a standard) if it additionally meets the following criteria:

 The burden is less than £70k (such collections will still be subject to a burden assessment)

 There are no Information Governance (IG) implications, or any IG issues have been addressed

High impact full Update Collection Summary report Produce specification Produce implementation guidance ISAS appraisal (10 working days) SCCI presentation

for accepaence Publication High impact requirement

Burden Assessment

consultation Burden assessment report

Produce Collection Summary report

Collection process Impact assessment, categorisation and prioritisation

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 The collection is concordat1 compliant or not applicable (i.e. it is already being collected by the HSCIC; plans are already in place to do so, or it is not practical to flow the data through the HSCIC)

 There is a statement which details what is being collected and how

Low impact

A one-off / ongoing / or voluntary collection (without the need for a standard) if it additionally meets the following criteria:

 The burden is less than £150k (such collections will still be subject to a burden assessment) (Note: in the case of Social Care the minimum burden figure is £100,000)

 The collection is concordat compliant or not applicable (i.e. it is already being collected by the HSCIC; plans are already in place to do so, or it is not practical to flow the data through the HSCIC)

 The collection and submission method is in existence and proven

 The collection considers the use of existing standards where this is appropriate

 The collection has a legal basis

 There is evidence that funding is in place to ensure the development, maintenance and collection of the data

 The collection complies with existing standards or plans are in place to work towards compliance where appropriate (it may not be appropriate for a one-off collection).

Medium impact

An on-going collection (with an associated standard) if it additionally meets the following criteria:

 The burden is between £150 - 250k (such collections will still be subject to a burden assessment)

 The collection and submission methods are in existence and proven

 There is no impact or overlap with other collections and or standards which has not been addressed within the standard

1_{An agreement between the partner organisation that constitute the membership of NIB to work collaboratively}

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 That appropriate consultation has taken place and any issues raised through the consultation have been addressed

 There is evidence of funding and resource to ensure on-going management of the standard

 The collection complies with existing standards or plans are in place to work towards compliance.

High impact

An on-going collection (with an associated standard) if it additionally meets the following criteria:

 The burden is greater than £250k (such collections will still be subject to a burden assessment)

 The collection and submission methods can be demonstrated to work

 There is impact or overlap with other collections and or standards

 That appropriate consultation has taken place and any issues raised through the consultation have been addressed

 There is evidence of funding and resource to ensure on-going management of the standard

 The collection complies with existing standards or plans are in place to work towards compliance.

3.5.4 Review

All collections will have a review date set 12 months after implementation. The review will be coordinated with the three year review of approved collections which is undertaken by BAAS where they coincide. Development Support will contact the business lead responsible for the collection in advance of the review date to initiate. As part of the review the following will be considered by SCCI:

 A report on the data which has been collected

 A statement of the benefits realised in relation to those which were expected

 Continued need of the collection (excluding one-off collections)

3.5.5 Publication

Publication of collections will be in the form of a formal Information Standards Notice (ISN) and inclusion within the approved assessed collections list.

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The ISN will include confirmation of the collection details, its nature (mandated or voluntary), the legal or contractual basis upon which the data is being requested and key contacts. It will additionally include any links to associated information and guidance.

Collections that have an associated Standard will be published through an ISN, alongside documentation which details the items which are being collected and the method of

collection. This documentation must additionally provide advice on any information governance issues.

Assessed Collections List

All accepted collections will be published within the assessed collections list which details what is being collected and how.

3.6 Publishing

On acceptance of an ISCE by SCCI, a decision is made as to the urgency of publication of the ISN. There are two points of publication:

1. A monthly publication date, three weeks after the date of acceptance (i.e. the SCCI meeting).

2. An expedited publication date, taking place as soon as possible after the date of approval.

Post acceptance, SCCI Secretariat has to notify DH, NHS England and the HSCIC of the action and request formal approval of the ISCE for publication as f:

 an information standard under the Health and Social Care Act 2012

 a data collection included with the HSCIC Assessed Collections list.

No publication can take place until formal approval has been received. The three weeks duration has been determined to allow time for SCCI Secretariat to issue the acceptance letter and for the appropriate SCCI representative to request the approval letter be issued. SCCI will consider a request for expedited publication as part of the Developer’s submission. Such a request should reflect extraordinary circumstances, e.g. ministerial commitment. If no request is made, publication is scheduled for the next monthly publication date.

3.6.1 Pre-publication checks

Once the final set of documents is received by the SPNS, ISAS is instructed to undertake a pre-publication review to provide assurance that the documents are ready for publication. Any issues with the documents are passed back to the Development Support Manager for resolution.

On return from ISAS, a final inspection of the documents is undertaken by the SPNS to insert any URLs and to convert the documents to PDF format, prior to uploading to the HSCIC website.

NB. There is a period of transition from use of the ISB website to the HSCIC website. However the HSCIC website will point users to the most up-to-date version of the ISCE.

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3.6.2 Branding

SCCI works on behalf of a number of organisations and is responsible for publication on behalf of the Department of Health, NHS England, HSCIC and other regulatory bodies as appropriate. Ownership of, and accountability for, the content of the ISCE remains with the originating organisation and published documents therefore should be consistent with that organisation’s house style. A SCCI endorsement is added as part of the publication process. [DN this is being finalised with DH, NHS England and HSCIC, and will be added here]

3.7 Roles & Responsibilities

The roles and responsibilities provided below are accurate at the time this document was published; for up to date information use the links provided in section 6 Sources of

Information.

3.7.1 SCCI Support Services

Role Responsibilities

Idea Development Team 1. Provides the SCCI ‘Front door’. All submissions to SCCI will in the first instance be processed by the idea development team

2. Idea development and elaboration; identifying options and making

recommendations; drafting of Statement of Need, proposal for change

Development Support Team 1. Owns the end to end process and development framework

2. Provides management and coordination of submissions through the process 3. Provides an advocate service for

Sponsors, SROs and Business Leads and support and advice

4. Co-ordinating the development of actual products across organisations, agreeing timescales for content development and document product production,

responsibilities. Identifies and manages risks, issues and conflict across the system

5. Manages the handover through agreed gateways, establishing gateway

‘readiness’ and links to internal business planning processes

6. Provides management information and performance reporting across the end to end process

7. Carries out impact assessment and prioritisation activities.

8. Quality assures all documentation to ensure they meet the required quality

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and ISAS appraisal criteria prior to SCCI Board submission

9. Provides Executive summaries and briefing reports to SCCI for all ISCE Publication and Knowledge Management

Team

1. Knowledge Management across all SCCI support services

2. Manages pre-publication quality checks 3. Manages and ensures appropriate

approvals, directions etc are in place 4. Manages publication of standards 5. Ensures consistency across publication

channels

6. Manages consultation and information web platforms

7. Facilitates open consultations and discussion

8. Manages the interface to European commission in relation to European Directive EC 98/34

9. Manages SCCI related communications, collaborating with internal and external communications teams as appropriate. SCCI Secretariat 1. Provides secretariat for SCCI committee

meetings

2. Organises meeting facilities, venues, membership and calendar

3. Drafts and publishes meeting minutes 4. Manages and tracks the action and risk

logs

5. Provides formal notification of SCCI decisions

NHS England Standards Team 1. Identification of SRO and Sponsors 2. Facilitation approval letters from NHS

England

Independent Standards Appraisal Service 1. Manages independent appraisal of submissions

2. Reports on feedback from EU 98/34 consultation

3. Produces a recommendation report and supporting advice to SCCI for each submissions

4. Provides input / review of any public consultation process

5. Provides internal assurance of publication documents

6. Provides extra ordinary reviews of standards if directed by SCCI

7. Owns and maintains the Information Standards, Collections and extractions

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assurance methodology

Burden Advice and Assessment Service 1. Owns and maintains the burden assessment methodology

2. Undertakes burden consultation for submissions across all Health and Care (including Social Care)

3. Provides recommendations on ways to minimise burden

4. Calculates and reports the burden of submissions

5. Owns and maintains the approved collections list

6. Manages and reports the

interdependencies with the 3 year review of all collections

SCCI Service Management Group 1. Assures HSCIC services against their service definitions

2. Provides initial escalation point for cross service operational issues

3. Provides assurance of performance against published SLAs

SCCI Service Board 1. Assures performance against delivery plan 2. Manages escalations from SCCI service management group

3. Prioritisation of HSCIC resources

4. Provides a quality check of Statements of Need and briefing papers to SCCI

3.7.2 Process Roles

Role Responsibilities

Sponsor 1. Ensures finance is in place

2. Ensures processes are in place to monitor expenditure and manage finance

3. Assures the responsible minister that the ISCE represents value for money

Senior Responsible Owner 1. Ensures processes are in place to manage and monitor development, implementation and maintenance of the ISCE throughout its lifecycle

2. Ensures strategic alignment of the ISCE 3. Ensures risks and issues are effectively managed

4. Ensures that an approved business case is in place and that the ISCE development,

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implementation and maintenance meets the requirements and delivers the stated benefits 5. Ensures compliance with existing

standards

6. Notifies the European Commission through the Department of Business Innovation and Skills if EU consultation is required

Business Lead 1. Supports the SRO to deliver stated benefits and requirements

2. Supports and ensures the development of the ISCE documentation and other

submission documents and evidence

3. Ensures an SRO and Sponsor is identified if not already in place

Developer 1. Manages the development of the ISCE or

individual components

2. Produces of the ISCE documentation and supporting evidence

Impact Assessment Panel 1. Categorisation of ISCE submission; determining the appropriate pathway 2. Prioritisation of ISCE submission as

described in section 3.4.1

3. Impact Assessment of ISCE submission 4. Identifies any requirement for business

planning submission

5. Identifies links to other business processes

6. Provides statements of support and comments from members

Development Support Manager 1. Plans and schedules submission to SCCI

2. Provides advice and support about the preparation and development of

documentation and supporting evidence to the Sponsor, SRO, Business Lead and Developer of ISCE

3. Ensures submissions are made to ISAS and SCCI on time to meet

implementation timescales 4. Managing relationships with all

stakeholders

5. Managing expectations

6. Representing the Business Lead to ISAS and SCCI when presenting

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3.8 Workload management

3.8.1 Principles

In managing submissions to SCCI the following principles are applied:

 Openness and transparency – information on the status and progress of submissions will be made available including details of key contacts and milestones through a single web portal.

 Single point of contact - a development support manager will be allocated to each submission; they will provide advice and support to the submitter throughout the process.

 Reduction of burden – we will endeavour to reduce duplication and burden through:

o Identification of overlap or duplication with existing ISCE submissions; facilitating collaboration where appropriate.

o Enabling re use of documents developed for other business processes wherever possible where they meet quality criteria.

o Ensuring that we share information across the support services and remove any duplication within our processes.

 Learning lessons – we will undertake regular surveys and post submission reviews to gather feedback and understand where we need to improve; we will act on feedback provided through service improvement plans.

3.8.2 Tracking

3.8.2.1 SharePoint Site

An externally facing SharePoint site has been set up to provide a single platform for receipt, tracking and updating on progress of items submitted for approval by SCCI. This provides members secure access to update and manage items for submitters both internal and external to HSCIC; documents and information can be worked on securely and then made available for submission to SCCI easily. The site additionally provides open public access to a subset of the information held. All information relating to a single submission is made available through a ‘workspace page’; the page address is the SCCI reference number / standard number to ensure consistent addressing.

The site provides:

 A Master tracker- A single tracker mechanism is in place on the site and is used to record all information on submissions throughout the lifecycle; this ‘Master tracker’ is used to derive all management information and near real-time reporting of progress.

 A reporting dashboard – A single page with multiple links to management information reports. Reports will include; schedule information and key performance indicators.

 A help section – A sub site which provides information and help on the SCCI process, including how to submit an idea, develop an ISCE and how to maintain it.

 A Knowledge Management section – A sub site for members which provides procedure, post submission review details, improvement plans and other useful information and links.

3.8.3 Project Management

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 Plans will be drawn up in consultation with the submitter following acceptance by SCCI of an idea. Key milestones will be entered on the Master Tracker and be viewed through reports.

 Risks and Issues will be recorded using the central Risks and Issue Tracker on the SharePoint site and will be filtered by the SCCI reference number.

 Stakeholders will be recorded using the central stakeholder list on the SharePoint site and will be filtered by the SCCI reference number.

 Post submission reviews will be undertaken to identify improvements that should be made.

3.8.4 Links to business process

3.8.4.1 Business Planning

A key component of the SCCI process is the ability for anyone to submit an idea for a new ISCE or change to an existing one. As a result submissions may not always have full business approval and funding within an appropriate organisation able to develop and maintain the suggested ISCE (or the owning organisation where it is a change to an existing ISCE).

In this case the idea will still be developed by the Idea Development Team and presented to SCCI for consideration. If accepted it may sit ‘on hold’ at the next development stage

(Requirement) until a Sponsor, SRO and business leads are in place and it is progressed through Portfolio and Service Management business planning processes where this is appropriate.

Items in this category will be identified and reported to SCCI on a regular basis; they will be given a status of ‘on hold’ and allocated an overall red, amber green (RAG) status by applying the following criteria:

 Green – 0 -3 months from SCCI idea acceptance

 Amber – 3 – 6 months from SCCI idea acceptance

 Red – more than 6 months from SCCI idea acceptance

The report is provided to SCCI for onward dissemination into members’ host organisations and the National Information Board. An up to date list of SCCI members is available on the

NHS England website. In October each year SCCI will review all items on hold to assess

their progress and continued relevance.

3.8.4.2 HSCIC Portfolio and Service Management new work process

Where a submission is within the scope of HSCIC business responsibilities and portfolio or is already being led by a HSCIC team; it is important that the business planning and portfolio process runs in parallel to the SCCI process. There are a number of dependencies between the two; the following criteria will be applied by the Impact Assessment Panel to determine if a SCCI submission will additionally need to be considered by the Portfolio and Service Management Board:

1. All necessary work to complete the process and maintain the ISCE cannot be

undertaken within the remit of an approved existing HSCIC portfolio item i.e. the work is not covered within an existing approved business case and cannot be done as business as usual.

2. Sufficient funding and resource is not in place to undertake all necessary work to complete the process and maintain the ISCE.

3. Sufficient funding is not in place to undertake any analysis and dissemination of data necessary (Collections and Extractions).

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5. Will it cost over £250,000

If any of the above criteria is true then the submission will additionally need to be considered by the HSCIC Portfolio and Service Board. The Submitter will be notified of the need to commence the Portfolio and Service Board process by Development Support; advice will be provided on how they should proceed and consultancy may be provided (if requested).

3.9 Issue resolution

All issues with the process or SCCI Support Services teams should be reported in the first instance to the SCCI Support Services, Service Manager through the central mailbox ([email protected]). The issue will be logged and the issue management process followed:

 Investigation – the issue will be investigated and a report compiled

 Analysis - the report will be considered by the SCCI Support Services operational management and any actions and outcome agreed

 Notification of outcome -the submitter will be contacted to discuss the report and outcome

 Escalation - If not satisfied the issue can be escalated to the Head of SCCI Support Services who will review the report and outcome plus any additional information provided by the submitter. The outcome of the review will be notified to the submitter within 10 working days.

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4 Stages

4.1 Idea to Need

This stage is intended to elaborate ideas for all new and changes to ISCE and develop a statement of the business need for submission to SCCI. In some instances ideas may not be submitted to SCCI in agreement with the submitter e.g. due to being identified as a business as usual or superseded by another submission. During this stage the idea will be researched to:

 Identify and document the business requirement.

 Identify and document any overlapping standards, collections or extractions or parallel work in the same area.

 Identify and document impacts through subject matter expert review and input.

 Identify and document potential solution options to inform next stage.

 Estimate costs and timings for input to next stage.

 Identify and document any Risks

4.1.1 Contacts

All enquires relating to the Idea to Need stage should be directed to the Idea Development team via e mail: [email protected]

4.1.2 Timescales

Elaboration of new ideas is completed in 10 working days from start (after submission of initial required information and agreed commitment of resource by the submitter to assist in the elaboration). Where the submission is a change then it will logged and passed to the change process.

4.1.3 Entry Criteria

An idea – Ideas can either be directly submitted or identified through intelligence gathering activities; for information on how to submit an idea see Sources of Information.

4.1.4 Inputs

The required Inputs for Idea Development are:

Idea: an idea can originate from any source; it will be logged centrally by the Idea

Development Team who will engage with the idea submitter to better understand, elaborate and document the original idea with option(s) and recommendation(s).

Subject Matter Expert Inputs: the Idea Development Team will gather information and opinion from subject matter experts within the HSCIC. Note: at subsequent stages in the process internal and external consultation will take place; including full public consultations where this is needed.

4.1.5 Outputs

Direct SCCI outputs are:

 A Statement of Need for submission to SCCI.

 A Proposal for Change for submission to the ISCE change process. Indirect SCCI outputs of the service are:

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 Information and Intelligence Discovery.

 Subject Matter Experts contacts, feedback and context.

 Process Maps or Diagrams. Other outputs may include:

 HSCIC internal new work request forms, project briefs and other portfolio process outputs where the consultancy service is commissioned.

4.1.6 Stage acceptance criteria

 A completed Statement of Need or Proposal for Change.

 All intelligence, documentation and supporting evidence logged and stored in the SharePoint library under the correct SCCI reference number.

 All stakeholders identified recorded in the SharePoint stakeholder list.

 SharePoint Master Tracker and workspace page updated with latest information

4.1.7 Process

The Statement of Need / Proposal for Change is quality checked by the HSCIC SCCI Service Board before submission to SCCI.

The Statement of Need / Proposal for Change is presented to SCCI by the Idea development consultant.

Details of the SoN will be recorded in the SCCI minutes alongside the decision and published on the HSCIC website (http://www.hscic.gov.uk/isce/publication/son), including any conditions, if any. The SCCI secretariat will formally notify within 2 working days the outcome to the development support service and Submitter on behalf of the SCCI Chair. An accepted SoN will additionally be made available in the specific standard ‘Approved

Documents’ section of the SCCI Development external SharePoint site.

4.1.8 Reporting

 Reports on all items within the SCCI process are available on the SCCI SharePoint dashboard https://groups.ic.nhs.uk/SCCIDsupport/dashboard/default.aspx

 A weekly scheduling meeting is held across all services to discuss all items in the SCCI process to enable planning by all teams.

 A telephone conference call occurs every Friday morning at 09:00 to discuss items at Idea to Need stage.

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4.2 Need to Requirement

This stage of the process involves developing the accepted need into a requirement submission which, if accepted, will be