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Project 10: Electronic Transfer of Prescription Data in Northern Ireland (EPES)Project description1. The Electronic Prescribing and Eligibility System (EPES) project is led by the Department of Health & Social Services and Public Safety (DHSSPS) in partnership with the Central Services Agency (CSA), the Social Security Agency (SSA), the four health and social services boards (HSSBs) and General Practitioners and community pharmacists.2. The project involves the development and implementation of a system which will automatically check the eligibility of claimants for prescription charge exemption in order to support improved control over prescription charge fraud. At present all prescriptions are transferred manually from the pharmacist to the Central Services Agency for processing and only a small sample are checked to see whether claims for exemption from prescription charges are valid. EPES will automate both the communication of prescription data from pharmacists to the CSA and a comprehensive matching of the prescription (and the patient identifier) with a database listing those who are in receipt of benefits qualifying them for exemption from prescription charges. The aims and objectives of the project are set out in the box below along with the risks anticipated for the project.
4. The counter fraud drive within the FPS in Northern Ireland, and the necessity to make a significant impact on exemption fraud, led to an Expression of Interest to HMT for ISB Round 1 funding. A range of counter fraud measures were introduced, including “point of dispensing checks” by pharmacists (i.e. requesting evidence of eligibility for exemption), but it was clear that an integrated electronic system would permit linkages between the key players in primary care to the CSA and SSA to enable such checks to be made automatically. When coupled with “point of dispensing checks” at the pharmacy, and legislation to make fraudulent claiming of exemption a criminal offence, the EPES project was considered to be the single biggest weapon against prescription fraud in Northern Ireland. 5. DHSSPS were invited to submit a full bid for the project and were offered a 75% contribution by ISB against total project costs of £2.8 million, as set out in Table 1.
6. When the bid was submitted, it was based on best estimates of the likely funding requirement – there was no detailed feasibility study work on which to derive firm cost estimates. A feasibility study was completed in January 2000 and, on the request of the Department of Finance and Personnel, Northern Ireland (DFP) an outline business case (OBC) was also commissioned. The OBC has not yet been finalised, but the draft report suggests that the broad order of costs for the preferred option is likely to be similar to those estimated at the bidding stage. 7. Estimates of the scale of the potential benefits arising from the project were made in the bid document and these have subsequently been refined by the feasibility study and draft Outline Business Case. Cost-savings and a reduction in prescription charge exemption fraud are the two key quantifiable benefits.
8. The ISB bid was prepared by a small working group drawn from within DHSSPS to reflect the need for executive (fraud policy), user (the Chief Pharmaceutical Officer) and technical (Directorate of Information Systems) inputs. Other than obtaining line management agreement to the bid and discussing it with DFP, time did not permit further internal or external consultation on the proposed project. There were two key influences on the selection of this working group and the rationale for it comprising DHSSPS personnel only. First and foremost was the limited timescale available to prepare the full bid – reported to be one week. Given the tight timescale and that DHSSPS was in the lead, it was considered neither necessary nor helpful to embark on a consultation exercise outside the Department. Second, the working group members were already experts in their individual areas and the Chief Pharmaceutical Officer, in particular, was aware of many of the key issues which would need to be addressed to secure the critical buy-in to the project from the GPs and community pharmacists. 9. Those involved in the bid preparation considered the ISB selection criteria to be clear. Their only criticism was over the short timescale available for bidding which limited the opportunities for internal and external consultation on the project proposals. There was no criticism of the lack of consultation by any of the other partners we spoke to, all of whom recognised the bidding timescale constraints. Many reported the good relationships between those working up the bid and the other organisations that would need to be involved subsequently. It is also clear that partner organisations have been able to sign up relatively easily to the project objectives, with clear strategic fit between the anti-fraud project objective and that of the HSSBs, and the efficiency saving objective and a similar desire to cut processing costs on the part of the Central Services Agency. While the project’s objectives bear a clear and direct relationship with the strategies of the DHSSPS, the HSSBs and the CSA, they do not fit so comfortably with those of GPs and community pharmacists. These stakeholders – key to the success of the project - have much less to gain directly in financial terms, even though many can see the wider benefits to the health system of reducing levels of fraudulent claiming. 10. HMT attended a pre-submission presentation by DHSSPS in Belfast, where the focus of the discussion was on the need to liaise with related initiatives in Great Britain and learn relevant lessons from their experience, as well as the maximum level of funding which HMT could commit. This was reported to have been helpful in refining the bid, which was accepted subject only to the standard ISB conditions.
12. The EPES Steering Group, which is chaired by a Deputy Secretary from DHSSPS[2], has representatives from the Health and Social Services Boards (HSSBs), the CSA and SSA - many of whom are represented at Grade 3 level - as well as a respected General Practitioner and community pharmacist. Its role to date has primarily been in securing organisational commitment from partners and clearing the ground of in-principle issues to allow the Project Board to progress the management of the project. 13. The Project Board is larger than that required under PRINCE, but still considered small enough to be effective. It is chaired by the Project Executive (DHSSPS) with representation from two of the HSSBs, Northern and Eastern, DIS as senior technical representative for DHSSPS, the CSA, and GP and community pharmacist representatives (nominated by the British Medical Association and Pharmaceutical Society respectively). The project manager is from the Western HSSB. The only key organisation not represented on the Project Board is the Social Security Agency. 14. The Project Executive has provided part-time, day-to-day, direction and management for the project since its inception in February 1999 and a Project Manager was appointed (on a part-time basis) in November 1999. Both are now stepping back from these roles – the Project Executive has been appointed head of the new Counter Fraud Unit at the CSA – but both will retain some involvement in the project, especially the consultation process. A new full-time Project Manager has just been appointed. 15. The Project Team and Project Assurance Teams will have representatives from all of the key players. The intention is to actively involve GPs and community pharmacists in both structures, but if time pressures do not allow for their attendance at meetings, special arrangements will be put in place to ensure regular two-way communication on EPES. Quite rightly a real effort is being made to ensure that vital stakeholder groups remain part of the project at every level. 16. All of those we spoke to were in favour of the project steering and management arrangements and identified them as good practice for such a high-priority partnership project. Two aspects were singled out for praise – the Steering Group, and the calibre of project management to date. The fact that such a high-level Steering Group was put in place for a project being implemented within the “health umbrella” – where inter-relationships between the key players (at organisation and individual level) are already strong – demonstrates the importance attached to the project’s success by DHSSPS. Two key project management strengths were also flagged up – a well-rounded grasp of the strategic and technical aspects of the project and a good working relationship with the GP and community pharmacists in Northern Ireland. The latter has enabled a consultation strategy to be drawn up and implemented, with some early signs of success. 17. Our only, relatively minor, concern about project direction and management is the low profile to date of the Social Security Agency. The SSA sits on the Steering Group and we understand that it will also be on the Project Team and Project Assurance Team. However, it has not been represented on the Project Board, and we understand that this is because much of the work to date has concerned the relationships and interfaces between GPs and pharmacists and the CSA – i.e. issues of limited interest for the SSA which have taken up a considerable amount of time. Everyone we spoke to was aware of the crucial importance of the SSA/CSA interface for the success of the project. We understand that there are plans for greater SSA involvement in the project once it moves beyond the preparation of the outline business case and into detailed design and implementation. It would be sensible, in our view, to consider whether SSA representation on the Project Board at that point would strengthen the project’s chances of successful implementation.
19. Up to now monitoring arrangements have primarily been concerned with ensuring that the feasibility study and outline business case documents have been prepared on time, to budget and to the quality levels required, and with the effective implementation of the consultation strategy. The OBC sets out the “Critical Success Factors” which will be used to monitor the achievements of the project. These are:
20. The OBC recommends that DHSSPS should prepare a “Benefits Realisation Plan” once the system has been procured and before implementation, which formally sets targets for the benefits expected to arise from the project. It also recommends arrangements for post-project monitoring and evaluation, including regular meetings to discuss operational and strategic aspects of the project, a formal Post Implementation Review one year after the system has been accepted for operational use, and a Project Benefit Evaluation at the same time. The revised milestones for the project are set out in Table 2.
25. So far there have been no difficulties associated with DHSSPS’s financial and management accountability for the project. As expected, given its lead role in health and personal social services it has taken a strong lead, and one which we have already noted was given further stimulus by the criticisms levelled by NIAO and the PAC at the anti-fraud measures which prevailed in 1998. The way DHSSPS has executed its lead role on EPES was seen in positive terms by all of the consultees. It was applauded particularly for:
28. The EPES project has taken longer than expected to move forward to implementation, and this should flag up three issues for future challenge funding of this kind. The first is the need for a more elongated bidding timescale to allow time for consultation and, perhaps, more feasibility study prior to bids being submitted. The second, related, point is that while the ISB Round 1 selection criteria were considered to be clear enough, there was obviously some misunderstanding on the part of HMT as to the level of feasibility and other preparatory work required to get the project to the implementation stage. So, some clarity on acceptable, or consistent, levels of project development at the bidding stage would also seem sensible when the Northern Ireland Office introduces its own equivalent to ISB in the future. The third point is the need to spend some time identifying potential project managers prior to the bid being submitted, and taking early soundings on availability at the earliest stage. 29. Although it is still too early to judge the ultimate outcome of EPES or its cost-effectiveness, all of the signs are good. Doubts were raised by one consultee about the risk of cost-overruns, a legitimate concern given the track record of major public service IT projects in the UK. However, without exception all of those we spoke to were confident that the project would make a major difference to the immediate priority of tackling fraudulent claiming of prescription exemption, as well as providing a communications infrastructure and flow of data which would be valuable beyond the sphere of EPES. [1] Northern Ireland Audit Office, September 1998: Northern Ireland Health and Personal Social Services – Controls to Prevent and Detect Fraud in Family Practitioner Service Payments [2] The project was chaired initially by Mr Paul Simpson in his capacity of Chief Executive of the Health & Social Services Executive (HSSE). DHSS internal structures were changed last year, and Mr. Simpson has responsibility for taking forward the project on behalf of the Permanent Secretary oft DHSSPS. |
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