Many thanks for laying on the recent small-attendance DTAC review meetings which gave us all a great opportunity to understand in much finer detail what you and Rhod are planning and how you envisage the Criteria being used. During the sessions I and others raised a number of important points that I think it important to record on behalf of DHACA, in the hope that you can still see yourselves making changes before you finalise your proposal. I would add that I have also subsequently discussed these points with other DHACA members representing both app developers and app assessors to be sure there is a consensus view. The key points included:
As I understood from what you were saying, you will be encouraging local NHS units to do DTAC assessments, and at the same time you are dispensing with the detailed DAQ questions which had mainly yes/no answers, in favour of higher-level questions typically with more judgemental answers. Indeed if I understood correctly, you mentioned that you would expect each local unit to reassess some parts of the DTAC, notably data privacy, irrespective of assessments already done. Our fear is that, where adopted, the combination of these will drive substantial duplication across the NHS which will cost both the NHS and our members dear.
It was suggested that one way of minimising this duplication might be to keep a central register of local DTAC approvals so that at least units faced with assessing digital technology could make contact with those who already have done the same assessment.
Assessing against the DAQs took a substantial amount of time; whilst the DTAC will have fewer questions, as per our last point, as these will of necessity be more judgemental, it is unlikely that this time will be much shortened, especially initially as local assessors are learning the ropes. The end result is that technology that has not previously been assessed will be likely be significantly disadvantaged vs that that has, or even worse, against old technology competition that is considered not to require DTAC assessment.
It was suggested that one way of reducing this inequality might be to allow pre-assessment. Where old technology is an option, as exemplified by the AF sensing iRhythm Zio, which has online connectivity compared with a Holter monitor, which does not, it was suggested that you might establish technology categories where all contenders for a contract should be assessed, whether connected or not, to level the playing field.
Further, it was suggested that local NHS units should be encouraged to subcontract work to assessment organisations such as Iqvia and ORCHA, who are very experienced at assessing digital technology, quickly…and could also minimise duplication too.
Concern was expressed that DTAC assessments should only be completed if sponsored by a procurement unit in the NHS. I mentioned an app I am involved with – SOS QR – and another participant mentioned a patient diary. Perhaps the best-known example is Fitbit which is recognised to reduce significantly the incidence of cardiovascular disease, including diabetes.
It was suggested that DTAC assessments for these technologies be encouraged, including central NHS sponsorship, where there is a clear benefit to the NHS as a whole even though no individual NHS unit could justify approval.
A further concern that we never got to cover was how these technologies would be reassessed in future – with the App Library there was a clear and continuing responsibility to reassess them regularly. With local units sponsoring assessment, it is unclear where that responsibility lies.
I would argue this makes an even stronger case for a central listing of all assessments – call it a “Library” or whatever.
I really hope those are seen as helpful suggestions and stand ready to engage further on behalf of our 850 members, should you or Rhod wish.
I’d add that our offer of a DHACA webinar, put to you twice in the Autumn, where you can address our members directly still remains – we would be delighted to host one for you. (CL note: Now running on 12th February)
Digital Health & Care Alliance (DHACA)
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