ICS digitisation and EPRs

Sophie Burton-Jones discusses NHSX’s Frontline Digitisation programme and the move towards an integrated care approach within the NHS and the foundational role of digital in Integrated Care Systems.

At a recent frontline digitisation supplier engagement event with NHSX, chaired by Andreas Haimboeck-Tichy, chair of techUK’s Health and Social Care Council and Director of Ecosystems at IBM, we heard a panel of NHSX experts share their insights on the challenges to frontline digitisation and what suppliers should expect from the upcoming programme.

The programme of frontline digitisation is set to take place over the next few years and aims to accelerate uptake of the foundational technology needed to underpin digital transformation. The aims of the programme, include going paper-free, establishing electronic patient records and achieving a boarder cultural shift.

In this article, we summarise a few of the key takeaways in the context of the ICS landscape and the news that neighbouring Devon and Cornwall ICSs are drawing up plans for a single hospital IT system. They are one of the first examples of an entire regional ecosystem working together to deploy the same electronic patient record across the region’s five acute Trusts.

The digital ambition

  • The programme aims to support the 80% of NHS providers who are not digital to become digital with EPRs over the next five years.

  • The desire is for ICSs (and not Trusts) to become the buyers so that records/data can be shared as necessary within an ICS thereby minimising issues with different systems not integrating or competing suppliers refusing to let systems talk to each other.
  • The ambition is to create more of an open/competitive market instead of closed market for a select few big suppliers.

But it’s complicated

While there are a number of benefits and advantages of getting all records digitised and adopting better data sharing systems, a number of challenges persist, as we describe here.

  • The majority of EPR contracts are long term (10-15 years) and the majority of big Trusts/Foundation Trusts are already locked in for a number of years, so ICS-wide EPR likely isn’t going to happen very quickly unless non-digitised providers join into existing contracts. Getting providers to join into existing contracts will likely lead to more consolidation by the big suppliers, potentially defeating the aim of having a more open market described above.
  • There is also a risk associated with the ICS entering into such a long-term contract when the NHS is continually being restructured – what if the ICS doesn’t exist in a few years’ time? Who will ‘hold’ the contract on the providers behalf going forwards and/or will there need to be any sort of de-merger of EPR services?
  • NHS providers may need to be persuaded that this is the right approach for them – the previous national programme for IT (NHS Connecting for Health) failed for a number of reasons, but one major reason was the lack of buy-in from providers, due to a perceived one size fits all/take it or leave it approach to purchasing and contracting that many didn’t believe met their needs or acknowledged their differing constraints and challenges.
  • The general public perception about sharing of health and care records, and the recent issues with opt-out, mean it is important that the messaging on wider provider data sharing and why this is happening is clear and explains the benefits for patients.

Next steps

We understand that there will be centralised support from NHSX who will look to support ICSs from the centre, with the aim of providing a consistency of approach to enable better outcomes, so we will need to wait and see what the NHSX guidance has to say.

Trailblazers like the Devon and Cornwall ICSs example may also provide useful precedents for others to follow and/or help flush out some of the issues that are likely to arise from this new approach.



Our content explained

Every piece of content we create is correct on the date it’s published but please don’t rely on it as legal advice. If you’d like to speak to us about your own legal requirements, please contact one of our expert lawyers.

Mills & Reeve Sites navigation
A tabbed collection of Mills & Reeve sites.
My Mills & Reeve navigation
Subscribe to, or manage your My Mills & Reeve account.
My M&R


Register for My M&R to stay up-to-date with legal news and events, create brochures and bookmark pages.

Existing clients

Log in to your client extranet for free matter information, know-how and documents.


Mills & Reeve system for employees.