FOI-03803

##Request

You asked us:

<i>1. Claims Assessment Process: Entry to Exit

I would be interested in understanding the end-to-end workflow of the claims assessment process — from the point at which a VDPS claim is received by the contracted assessor from Crawford and Maximus through to the point at which the completed medical assessment is returned to the NHSBSA.<br>

Specifically, I request:<br>

a) The steps taken upon receipt of a claim by the subcontractor (Crawford and Maximus), including any initial triage, eligibility checking, or administrative processing;<br>

b) How and by what criteria a claim is allocated to a specific Independent Medical Assessor;<br>

c) Whether there is a systematic, automatic second-opinion review built into the process for all claims as standard, and if so, how this operates;<br>

d) If a second opinion is not standard:<br>
*The precise circumstances or triggers under which a second opinion is sought; *Who has the authority to request a second opinion; <br>*What specialty or seniority is required of the second-opinion assessor; and <br>*Whether the first assessor is made aware that a second opinion has been sought, and <br>*whether they are given the opportunity to respond.

e) How the completed medical assessment report is quality-checked before submission, and by whom.

2. Professional Qualifications and Accreditation of Medical Assessors

2a. The full job specification(s) for Independent Medical Assessors (IMAs) engaged in the assessment of VDPS claims under the contract, including any person specifications, essential and desirable criteria, and role profiles currently in use.

b) What specific medical specialties or sub-specialties are considered relevant or preferred for assessors evaluating VDPS claims, and whether there is a list of accepted or preferred specialties;

c) What compulsory training must Independent Medical Assessors complete before being authorised to assess VDPS claims, including:

*The name and content of any mandatory training modules or programmes; <br>*The awarding or accrediting body for each, where applicable; <br>*The duration of training; and <br>*Whether training must be refreshed periodically, and if so, at what interval.

3. Audit and Quality Assurance

a) What internal audit processes the NHSBSA or its contracted assessor operates in relation to VDPS medical assessments, including the frequency of audits, who conducts them, and what criteria are assessed;

b) What external audit or oversight mechanisms exist, and which regulatory or commissioning bodies are involved;

c) What happens when an assessment is found to be deficient, inconsistent, or not in compliance with required standards, including the escalation and remediation process;

d) Whether assessors are subject to individual performance monitoring in respect of their VDPS assessment work, what metrics are used, and what thresholds trigger a review; and

e) Whether there are any published outcomes or results from audits conducted to date in relation to VDPS assessments that the NHSBSA is able to share.

Where any information is withheld, I would be grateful if you could identify the precise exemption(s) relied upon under the Freedom of Information Act 2000, confirm whether the exemption is absolute or qualified, and, where qualified, set out the public interest balancing exercise that has been applied.

If any part of this request has been directed to the wrong team or department, I would be grateful if you could either redirect it internally or advise me of the appropriate contact.</i>

The NHS Business Services Authority (NHSBSA) received your request on 7 May 2026. 

We have handled your request under the Freedom of Information Act 2000 (FOIA).

##Our response

I can confirm that the NHSBSA holds some of the information you have requested.

<strong>Question 1 - Claims Assessment Process: Entry to Exit
 
I would be interested in understanding the end-to-end workflow of the claims assessment process — from the point at which a VDPS claim is received by the contracted assessor from Crawford and Maximus through to the point at which the completed medical assessment is returned to the NHSBSA.
 
Specifically, I request:
 
a) The steps taken upon receipt of a claim by the subcontractor (Crawford and Maximus), including any initial triage, eligibility checking, or administrative processing;
b) How and by what criteria a claim is allocated to a specific Independent Medical Assessor;
  
Question 2. Professional Qualifications and Accreditation of Medical Assessors
 
2a. The full job specification(s) for Independent Medical Assessors (IMAs) engaged in the assessment of VDPS claims under the contract, including any person specifications, essential and desirable criteria, and role profiles currently in use.
 
b) What specific medical specialties or sub-specialties are considered relevant or preferred for assessors evaluating VDPS claims, and whether there is a list of accepted or preferred specialties;
 
c) What compulsory training must Independent Medical Assessors complete before being authorised to assess VDPS claims, including:<br>
<ul>
<li>The name and content of any mandatory training modules or programmes; </li>
<li>The awarding or accrediting body for each, where applicable; </li><li>The duration of training; and</li> 
<li>Whether training must be refreshed periodically, and if so, at what interval.</li></ul>

Question 3d - Whether assessors are subject to individual performance monitoring in respect of their VDPS assessment work, what metrics are used, and what thresholds trigger a review;</strong>

I can confirm that the NHSBSA does not hold the requested information. The NHSBSA contracts a third-party supplier to carry out medical assessments for the Vaccine Damage Payment Scheme (VDPS). As such, the:
<ul>
<li> job specification </li>
<li>medical specialties of the medical assessors </li>
<li>steps or processes taken on receipt of the claim </li>
<li>processes used to allocate a claim to a medical assessor are held by the third-party supplier and not the NHSBSA. </li></ul>

Similarly, the NHSBSA does not hold the medical qualifications and experience of the medical assessor as they are the responsibility of the third-party medical assessment supplier. The contract with our supplier does not require them to tell us this information. The NHSBSA also does not hold where the medical training was completed or obtained.

The contract requires all assessments carried out are  undertaken by suitably qualified and experienced Registered Medical Practitioners. This includes being registered on the UK General Medical Council with a licence to practise, and meeting or exceeding the following requirements:
<ul>
 <li>they are a Registered Medical Practitioner with at least five years’ post graduate experience, and </li>
 <li>they have experience of the performance of the medical and/or disability assessment, addressing questions of causation and impact in the context of legislative or policy requirements to assist the decision maker. </li></ul>

Please be advised since the disclosure of FOI-02581, this list of training materials has remained unchanged.

You can view FOI-02581 using the following link: <br>
https://opendata.nhsbsa.net/dataset/foi-02581

Further information is available in our Principles of Medical Assessment document. The full document can be found at:<br>
https://www.nhsbsa.nhs.uk/vaccine-damage-payment-scheme-vdps-claim-process

<strong>Question 1 - Claims Assessment Process: Entry to Exit

c) Whether there is a systematic, automatic second-opinion review built into the process for all claims as standard, and if so, how this operates;

d) If a second opinion is not standard:
<ul><li>The precise circumstances or triggers under which a second opinion is sought; </li>
<li>Who has the authority to request a second opinion;</li></ul>

e) How the completed medical assessment report is quality-checked before submission, and by whom.

Question 3 - Audit and Quality Assurance
 
a) What internal audit processes the NHSBSA or its contracted assessor operates in relation to VDPS medical assessments, including the frequency of audits, who conducts them, and what criteria are assessed;

c) What happens when an assessment is found to be deficient, inconsistent, or not in compliance with required standards, including the escalation and remediation process;</strong>

Each claim is assessed on a case-by-case basis by a medical assessor. All medical assessors are General Medical Council (GMC) registered doctors with a licence to practise and at least five years' experience.

All relevant information is considered to make a complete and fair assessment. The medical assessor thoroughly considers:
<ul>
<li>information given on the claim form </li>
<li>any further evidence submitted by you </li>
<li>any pre-existing conditions that are not caused by the vaccine </li>
<li>medical records (if required) </li>
<li>clinical research </li>
<li>epidemiological evidence </li>
<li>the current consensus of expert medical opinion </li></ul>

The medical assessor will advise if the claimant is entitled to a Vaccine Damage Payment, based on the government’s rules for the scheme. As soon as the claim has been assessed, the claimant will receive a letter telling them the outcome, and a copy of the comprehensive medical report VAD 30 (MA) form. The medical assessment report is written by the medical assessor and explains how they reached their decision. 

Depending on the nature of the case and the availability of scientific evidence, the medical assessor may believe further expert opinion is required to provide advice on causation. It will be detailed in the medical assessment report that additional advice has been sought from an expert.  The level of involvement of the expert will also be recorded in the medical assessment report, and any advice given by the expert added to the file.   

Every VDPS medical assessment report is peer reviewed internally by the third-party medical assessment provider. The third-party medical assessment provider is responsible for ensuring the overall quality of the medical assessment report, and that all credible sources of evidence are appropriately and consistently applied. 

A selection of medical assessment reports are quality assured by the NHSBSA and measured against the principles and standards expressed in the Principles of Medical assessment. You can view the Principles of Medical Assessment on the NHSBSA website: <br>
https://www.nhsbsa.nhs.uk/vaccine-damage-payment-scheme-vdps-claim-process

This is to ensure that the principles are consistently and appropriately applied.  An Integrated Quality Assurance (IQA) form will be completed by the NHSBSA with feedback given if required. Any feedback provided to the Medical Assessor will clearly indicate where further attention is required. Relevant amendments are then made by the Medical Assessor and checked by the peer reviewer before the medical assessment report is returned to the NHSBSA for further quality assurance. 

The contract with the third party medical supplier includes the ability for supplier rectification plans to address (quality) issues and ultimately termination.

<strong>*What specialty or seniority is required of the second-opinion assessor; and <br>*Whether the first assessor is made aware that a second opinion has been sought, and <br>*whether they are given the opportunity to respond.</strong>

Please be aware that I have decided not to release the details of any medical assessors as this information falls under the exemption in section 40 subsections 2 and 3(A)(a) of the FOIA. This is because disclosure of their details would result in their identification. As the requested information would allow a medical assessor to be identified, I consider this information is exempt. This is because it would breach the first data protection principle as:

a) it is not fair to disclose their personal details to the world and is likely to cause damage or distress<br>
b) these details are not of sufficient interest to the public to warrant an intrusion into their privacy

The requested information is exempt if disclosure would contravene any of the data protection principles. For disclosure to comply with the lawfulness, fairness, and transparency principle, we either need the consent of the data subject(s) or there must be a legitimate interest in disclosure. In addition, the disclosure must be necessary to meet the legitimate interest and finally, the disclosure must not cause unwarranted harm.

This means that the NHSBSA is therefore required to conduct a balancing exercise between the legitimate interest of the applicant in disclosure against the rights and freedoms of the medical assessor.

While I acknowledge that you have a legitimate interest in disclosure of the information, the disclosure of the requested information could cause unwarranted harm.

Information disclosed under FOIA is available to everyone and therefore the NHSBSA has to consider the overall impact of the disclosure and its duty of care. The expectation of the medical assessors is that they will remain anonymous and will therefore not be subject to contact or pressure from claimants or campaigning groups.

Given the certainty that disclosure of their name will identify them, there is a reasonable expectation that this information will not be disclosed under the FOIA.

Disclosing this information would be unfair and as such this would breach the UK General Data Protection Regulation first data protection principle.

Please see the following link to view the section 40 exemption in full: https://www.legislation.gov.uk/ukpga/2000/36/section/40

<strong>b) What external audit or oversight mechanisms exist, and which regulatory or commissioning bodies are involved;</strong>
 
The NHSBSA delivers the VDPS on behalf of the Department of Health and Social Care (DHSC) and is accountable for the administration to the relevant DHSC team.

<strong>e) Whether there are any published outcomes or results from audits conducted to date in relation to VDPS assessments that the NHSBSA is able to share.</strong>

A selection of outcome reports are quality assured by the NHSBSA and measured against the principles and standards expressed in the Principles of Medical Assessment. This is to ensure that the principles are consistently and appropriately applied. An Integrated Quality Assurance (IQA) form is completed by NHSBSA.

I am unable to provide a copy of the IQA forms as the requested information contains personal information including special category data, and therefore and falls under the exemption in section 40 subsections 2 and 3(A)(a) of the FOIA.  This is because it would breach the first data protection principle as:

a) it is not fair to disclose their personal details to the world and is likely to cause damage or distress.
b) these details are not of sufficient interest to the public to warrant an intrusion into their privacy.

For disclosure to comply with the lawfulness, fairness, and transparency principle, we either need the consent of the data subject(s) or there must be a legitimate interest in disclosure. In addition, the disclosure must be necessary to meet the legitimate interest and finally, the disclosure must not cause unwarranted harm.

While I acknowledge that you have a legitimate interest in disclosure of the information, the disclosure of the requested information would cause unwarranted harm. Disclosing this information would be unfair and as such this would breach the UK General Data Protection Regulation first data protection principle.

Please see the following link to view the section 40 exemption in full: https://www.legislation.gov.uk/ukpga/2000/36/section/40

In addition, disclosure of the requested information is also a breach of the common law duty of confidence. An individual who has been identified could make a claim against the NHSBSA for the disclosure of the confidential information.

The information requested is therefore being withheld as it falls under the exemption in section 41(1) ‘Information provided in confidence’ of the FOIA.

Please click the below web link to see the exemption in full: https://www.legislation.gov.uk/ukpga/2000/36/section/41

The following exemptions apply to anonymised or summarised IQA reports:

Section 21 of the FOIA – Information which is already reasonably available to you

The Principles of Medical Assessment outlines the quality standards expected within the Vaccine Damage Payment Scheme (VDPS) medical assessment reports. As mentioned in this document, it also incorporates previous learning that may be useful to consider in the preparation of Outcome Reports written by Medical Assessors. Any feedback provided as part of the quality assurance process is measured against the principles and standards contained within this document.

The Principles of Medical Assessment is available on our website at the following link:
https://www.nhsbsa.nhs.uk/sites/default/files/2025-04/Principles%20of%20medical%20assessment.docx

Section 43(2) - Information which is considered to be commercially sensitive

The specific quality assurance findings you requested are also withheld as they fall under the exemption in section 43(2) of the FOIA, as releasing the information would be likely to prejudice the commercial interests of the NHSBSA and our third-party medical assessor, Crawfords & Company.

Please be advised that we have consulted with our third-party supplier, Crawfords & Company, for their views in relation to disclosure of the requested information and how this would adversely affect their commercial interests. Feedback from this consultation has been incorporated into the public interest test detailed below.

In applying this exemption, we have balanced the public interest in withholding the information against the public interest in disclosing the information.

Please see the below web link to see the exemption in full:
https://www.legislation.gov.uk/ukpga/2000/36/section/43

Public Interest Test:

Considerations in favour of disclosure:
<ul>
<li>Public accountability and increased trust from members of the public in relation to transparency of information regarding Covid-19 vaccines and the Vaccine Damage Payment Scheme.</li>
<li>Public interest in citizens being confident in making informed decisions in relation to vaccines and that these decisions are taken based on the best publicly available information.</li></ul>

Considerations against disclosure:
<ul>
<li>The requested information includes the proprietary information of Crawford & Company. Disclosing this information in the public domain would enable competitors to replicate or exploit these methods, giving them an unfair advantage in future tendering rounds.</li>
<li>Protecting fair competition ensures value for money in procurement and tendering processes. Disclosure would distort the market and potentially increase costs to the taxpayer if competition is compromised.</li>
<li>In a commercial environment, the timing of a disclosure is of critical importance. Information relating to commercial activity is at its most sensitive when the procurement activity is still underway. This FOI request was received when this contract was being reprocured.</li>
<li>Potentially serious detrimental effect on the commercial interests of the NHSBSA due to a reduction in the effectiveness of the competitive tendering process should the NHSBSA choose to re-test the market at a later time. This is because potential suppliers would not have the confidence that the NHSBSA would publicly disclose proprietary information. Disclosing information that is commercially sensitive to a particular supplier during a live procurement where it could be viewed by a competing supplier would put that supplier at a disadvantage whilst potentially creating a competitive advantage for other suppliers. As such the procurement would not meet transparency and equal treatment obligations and could introduce the risk of a successful procurement challenge had the information been disclosed under FOIA.
<li>The NHSBSA believes that disclosing the requested information may decrease the effectiveness of any future competitive tender as it may prejudice the NHSBSA’s ability to obtain best quality of service and value.</li>
<li>Training materials on effective report writing have been released under FOI. As such, the NHSBSA are meeting transparency requirements without needing to release additional commercially sensitive information.</li>
<li>Quality standards and principles are publicly available on the NHSBSA website, and these incorporate lessons learnt from the Quality Assurance process. As such, there is transparency in the quality standards expected of the NHSBSA with its suppliers.</li>
<li>Maintaining confidentiality of proprietary methods safeguards innovation and efficiency.</li></ul>

Conclusion of public interest test:

The NHSBSA recognises that there is a public interest in the disclosure of information which facilitates openness, transparency, and accountability in public authority dealings; however, there is an inherent public interest in the NHSBSA being able to work in competitive markets, whereby the financial and reputational benefit is in to the wider public interest.

Having undertaken the balancing exercise, the NHSBSA concludes that the public interest in maintaining the exemption outweighs the public interest in disclosure.

##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” This information is licenced under the terms of the Open Government Licence:<br>
http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/

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: VDPS, VDPS Claims, Vaccine Damage Payment Scheme
Organization: Freedom of Information Disclosure Log