Unlocking the Future
Are we nearly there yet?
Throughout 2018, myself and my colleagues spent much time talking to distributors, insurers, medical practitioners and technology companies about the next evolution of protection underwriting. We were encouraged that our NexGen concept was warmly received by all as a change that could, in theory, restore customer trust in our industry and allow for greater proposition innovation whilst benefitting everyone in the value chain
In 2019 we have continued our work to evolve our concept and seek out strategies to increase the usage of Electronic Health Reports (EHRs) by both insurers and GP surgeries. Whilst take-up continues to be lower than desired at this point in time, there are a number of reasons to be positive for the future. A recent independent study, by SAMI Consulting in conjunction with the Chartered Insurance Institute (CII), has highlighted a number of ways for the industry to move the usage of EHRs forwards.
SAMI Consulting - Shaping the Future of Medical Records and Protection insurance1.
Munich Re was delighted to join a number of other forward looking businesses as part of this work with SAMI and the conclusions are clear – the future is digital and the use of EHRs can provide ‘a quicker service for the public and the insurance industry and a less burdensome one for GPs’.2
Aside from this conclusion, the other important output from this report is a set of 5 key recommendations for the industry to consider and pursue in order to bring the future closer to today, these key recommendations are:
The insurance industry should harness Independent Financial Advisors (IFA) as a new advocate for EHR use, and encourage insurance providers to use EHR as the default route to access medical records.
The National Data Guardian Office (NDGO) and the Information Commissioners’ Office (ICO) should seek to develop a joint Code of Practice under article 40 of the GDPR with the representatives of GPs (the British Medical Association (BMA) and the Royal College General of Practitioners (RCGP), the General Medical Council (GMC), the insurance industry, other external data users and the Medical Defence Unions. This in turn will help such organisations support the use of EHR systems.
NHS England and the NDGO should consider the legal and ethical ramifications of the data controller’s role at Clinical Commissioning Group (CCG) level in respect of medical information from patients being passed to insurers etc, even if it is simply to rule out such a change.
The Institute and Faculty of Actuaries (IFoA) and Financial Conduct Authority (FCA) should consult on what reassurances may need to be given to the public about its stewardship of their personal data; it should keep in view emerging thinking on the impact of big data on actuarial and underwriting standards and ethics and compliance with the Equalities Act 2010, the Data Protection Act 2018, and relevant ethical guidelines.
Building on the discussions that are taking place between the ICO, BMA, RCGP and NDGO, the insurance industry should seek to be involved in, or even sponsor, a wide independent debate about how a patient’s wallet might operate in relation to customer interactions with non-NHS users. If necessary, it should consider the use of external facilitation to help overcome historical disagreements and distrust.
Perhaps the most important action for our industry to actively take forward is point 2, creating a joint Code of Practice under the auspices of GDPR Article 40 by engaging with the BMA, the RCGP, the NDGO, the ICO and other relevant industry parties. The creation of such a code could help create clarity and a more compliant process for all involved in accessing, disclosing and using EHRs. It would also remove any barriers to the adoption of new digital transfer processes as the very code of conduct governing these systems would have already been approved by key trade and industry bodies.
What is also clear from this report is the need to address this challenge now as the NHS will continue to become more digital in the future. The motivation for the NHS to change is significant, it simply must change to survive given the ever increasing demands from society for care, whilst resources and GP numbers are becoming ever more limited. The issue of when the NHS will reach the digital tipping point for supporting insurance is difficult to predict but given that the adoption of digital services is written into the new GP contracts we should expect the pace of change to increase.
Given the ongoing digitalisation of the NHS and the fact that the SAMI report has identified a way for our industries to collaborate for the benefit of our customers and patients, it does look like we can bring the future a bit closer to today.
At Munich Re our mantra is ‘Not if, but how’ so we will continue to drive this agenda and the future. We hope you will join us on the journey.
1 https://www.cii.co.uk/learning-index/articles/shaping-the-future-of-medical-records-and-protection-insurance/83586 2 https://www.cii.co.uk/learning-index/articles/shaping-the-future-of-medical-records-and-protection-insurance/83586