FOI-03809

##Request

<i>You are responsible for the administration of exemption services (for example, prescription  and dental exemptions) to patients that helps them access health costs to which they are entitled.

These functions are delivered by separate divisions of NHSBSA.

You have an online 1 page very basic safeguarding policy document which refers to sharing data outside of the organisation but with no reference to sharing between the divisions you are responsible for https://www.nhsbsa.nhs.uk/our-policies/privacy/safeguarding-privacy-notice

That document fails to identify vulnerable groups and the protections they may need.

Please provide the following information:

1) A copy of the full safeguarding policies and all protocols/ guidance issued to Customer Resolution Teams (CRTs)in both the Dental Exemption Service and Prescription Exemption Teams

2) Do either above services have a vulnerable patient team separate to the CRTs?
If so please provide the internal referral guidance.
Confirm if a flag is put on a patient's record if or when identified as vulnerable

3) Confirm which IT system or systems the above services use and at which point they are an integrated system, if at all.

4) NHSBSA is responsible for issuing penalty notices .
There is a fraud team.
Therefore it is fair to assume all IT systems used can be interrogated and cross referenced for the purpose of investigation and prosecution.

Outside of the above scenario at what level of management can NHSBA officers of both the above services cross reference across exemption services?

4) Please confirm that it is possible for clerical entries to be made on the IT system where needed.

5) Certain cohorts of vulnerable patients require the use of pseudonyms on NHS records for safeguarding reasons.

This is within all NHSE and Primary Care guidance.

However these same patients will have benefits that make them eligible for full exemptions paid in their given name.

Please explain the process of cross referencing for this cohort that then prevents penalty charge notices being issued.

Please confirm that evidence provided to one division is then logged on another so to avoid the burden of distress caused by issuing penalty charge notices in error.

6) Please confirm that the HC1 is available in large print hard copy form and that both the first contact customer services team and CRTs have the facility to send out said forms</i>

The NHS Business Services Authority (NHSBSA) received your request on 9 May 2026. 

We requested clarification on 22 May 2026

<i>Therefore I would be grateful if you could you please clarify whether you are asking for details of the IT system(s) used across the full end-to-end process, or specifically from the point at which the PCN is created, and staff begin using the system?</i>

You responded on 25 May 2026

<i>I am asking for details of the IT system(s) used across the full end-to-end process.</i>

We have handled your request under the Freedom of Information Act 2000 (FOIA).

##Our response

##Question 1
##A copy of the full safeguarding policies and all protocols/ guidance issued to Customer Resolution Teams (CRTs)in both the Dental Exemption Service and Prescription Exemption Teams?  

Please find attached documents which describe our safeguarding policies, protocols and guidance. Below are the names of the documents relating to this question:

NHSBSA_SAFEGUARDING_POLICY.pdf<br>
RAISING_A_SAFEGAURDING_CONCERN.pdf<br>
CONCERNED_ABOUT_A_CUSTOMER.pdf<br>
SAFEGUARDING_CUSTOMERS_COLLEAGUES.pdf

##Question 2
##Do either above services have a vulnerable patient team separate to the CRTs? If so please provide the internal referral guidance.

We do not have a separate vulnerable patient team and therefore there is no internal referral guidance.

##Confirm if a flag is put on a patient’s record if or when identified as vulnerable?  

We do not hold information that would allow us to identify a patient as vulnerable. For example, we do not have access to a service user's medical records. However, if a service user identifies themselves as vulnerable, we can add a note to their customer record.

##Question 3
##Confirm which IT system or systems the above services use and at which point they are an integrated system, if at all.

Please find attached document “NHSBSA_TECS_FOI_IT_SYSTEMS.pdf” which describes this information.

##Question 4
##NHSBSA is responsible for issuing penalty notices. There is a fraud team.? 

We have a Loss and Fraud Prevention team.

##Therefore it is fair to assume all IT systems used can be interrogated and cross referenced for the purpose of investigation and prosecution.?
 
The Loss and Fraud Prevention team may not have direct access to all of the systems mentioned in the attached document “NHSBSA_TECS_FOI_IT_SYSTEMS.pdf”.

##Outside of the above scenario at what level of management can NHSBA officers of both the above services cross reference across exemption services?

Colleagues trained in the systems with login access. 

##Question 5
##Certain cohorts of vulnerable patients require the use of pseudonyms on NHS records for safeguarding reasons. This is within all NHSE and Primary Care guidance?

We do not have access to full medical records. We process information as it appears on the prescription form (FP10 form) submitted and used as part of our data matching exercise.

##However these same patients will have benefits that make them eligible for full exemptions paid in their given name.- the data FOR THE Citizen that is on the FP10 would be check with DWP as part of the data matching exercise?

The data recorded on the FP10 is checked against DWP and NHSBSA systems as part of the data matching process. If a valid benefit or exemption is identified that matches the FP10 details, no enquiry letter will be issued.

##Please explain the process of cross referencing for this cohort that then prevents penalty charge notices being issued. Please confirm that evidence provided to one division is then logged on another so to avoid the burden of distress caused by issuing penalty charge notices in error.?

When a prescription is received which has been signed as the patient being exempt from prescription charges, a data matching exercise is instigated. If no valid exemption is found for that patient, an enquiry letter is issued which invites them to contact us to confirm the exemption they have in place. During this data matching exercise, we only look for valid exemptions, we do not look for any expired exemptions the patients may have had.

If a patient signs an FP17 certificate at the dentist, this is then uploaded digitally to a platform which data matches against NHS Dental Services.

##Question 6
##Please confirm that the HC1 is available in large print hard copy form and that both the first contact customer services team and CRTs have the facility to send out said forms?
Yes.

##Data Queries

Please contact <a href="mailto: foirequests@nhsbsa.nhs.uk"> foirequests@nhsbsa.nhs.uk</a> ensuring you quote the above reference if you have any specific questions regarding this response; or, if you feel you may be misunderstanding or misinterpreting the information; or, if you plan on publishing the data.

##Reusing the data and copyright

If you plan on producing a press or broadcast story based upon the data please contact <a href="mailto: communicationsteam@nhsbsa.nhs.uk">communicationsteam@nhsbsa.nhs.uk</a>. This is important to ensure that the figures are not misunderstood or misrepresented.

The information supplied to you continues to be protected by the Copyright, Designs and Patents Act 1988 and is subject to NHSBSA copyright. This information is licenced under the terms of the Open Government Licence detailed at:

http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/ 

Should you wish to re-use the information you must include the following statement: “NHSBSA Copyright 2026”. Failure to do so is a breach of the terms of the licence.

Information you receive which is not subject to NHSBSA Copyright continues to be protected by the copyright of the person, or organisation, from which the information originated. Please obtain their permission before reproducing any third party (non NHSBSA Copyright) information.

Tags: DECS, Dental Exemption Checking Service, PECS, Prescription Exemptions
Organization: Freedom of Information Disclosure Log