UK Covid-19 Inquiry Module 3 report: Scottish Government response

Recommendation 8 - Systematically recording and publishing healthcare worker deaths

Chair’s recommendation:

The UK Government, Scottish Government, Welsh Government and Northern Ireland Executive should work with their respective public health agencies and healthcare employers to develop nation-specific mechanisms to collect, analyse and publish data systematically on the deaths of healthcare workers in the event of a pandemic outbreak.

The UK Statistics Authority should work with data providers to ensure that the data are comparable across the four nations of the UK

Scottish Government response:

This recommendation is accepted in principle. The recommendation is not accepted in full as whilst all four nations will endeavour that the data is comparable across the UK, different data sources may not make this completely possible.

Two workshops have been held with four nations colleagues and there was strong support for collecting healthcare worker (HCW) death data, with clear value across surveillance, protection, transparency, and recognition.

There are significant practical and ethical issues to resolve in delivery of this recommendation. Any approach would need to be accurate enough to command confidence, timely enough to be useful, and clear about coverage. There will also need to be consideration of the significant burdens reporting may have on employers especially during a pandemic.

No single data source meets all use cases; a mixed approach is likely required.

A phased approach is proposed. The first phase focuses on improving existing data collections and ensuring greater consistency through clearer definitions, enhanced reporting, and alignment across the UK. This will include developing minimum definitions and standards (e.g. “healthcare worker”) to improve consistency across the UK and exploring how current data sources and systems of reporting could be improved. However, their distinct purposes suggest different data sources, or a combined approach, will be needed, rather than a single measure.

The second phase, tests the feasibility of linking workforce and mortality datasets, alongside establishing the necessary legal, data-sharing, and governance frameworks, and embedding these processes into pandemic preparedness structures. Initial discussions for this phase propose data linkage of the Electronic Staff Record (ESR) on health worker employment status and Office for National Statistics (ONS) data on death as a promising, but currently underdeveloped, solution. Note that in Scotland this will be between eESS (Electronic Employee Support System)^[1] and National Records of Scotland (NRS). There are significant challenges in reporting data especially for those employed outside of NHS providers such as primary care, community services and independent providers and comparing with other professions and industries including social care.

The third phase is to move towards a more integrated analytical approach, combining early operational indicators with validated statistical outputs.

Scotland-specific implementation

Within Scotland, work in 2026 and 2027 will consider the following:

Exploring and setting out what systems were used and others that were available e.g. RIDDOR, during the pandemic, as part of Phase 1.

Phase 2 will explore the feasibility of eESS -NRS data linkage, including technical and governance requirements. This is likely technically feasible, for example, it could possibly be achieved securely by utilising the Community Health Index (CHI) number as the primary linkage key. eESS has the advantage of being able to collect other characteristics of health workers too where complete. The importance of the collection of this type of information was highlighted by CIREG.

It does though bring up a critical gap - eESS only covers directly employed NHS staff. It excludes primary care independent contractors. Primary Care/Contractors could be captured by linking NRS to the National Primary Care Contractor Database (NPCCD) to capture GPs, dentists, and pharmacists. However, this will exclude other primary care staff directly employed by contractors.

When considering alignment to social care workers, exploration of linking NRS to the Scottish Social Services Council (SSSC) Register, which captures over 170k care home and social care registrants, will be required. Consideration of whether the definition extends to unpaid carers, as raised by CIREG, will be given as part of this work and in considering the recommendations from the UK Covid-19 Inquiry’s Module 6 report into Social Care, yet to be published.

eESS is managed and hosted operationally by PSD Scotland on behalf of all NHS Boards.

Therefore, engagement of PSD Scotland, Public Health Scotland (PHS), who operate the electronic Data Research and Innovation Service (eDRIS), would be required. It is proposed that eDRIS would provide the established safe haven environment, legal, and ethical frameworks required to securely link NRS death registrations with workforce data.

Currently eDRIS update NRS deaths dataset on an annual basis. It is provided from NRS via PHS on a weekly basis, so confirmation is needed that weekly deaths data would also be accessible to eDRIS.

Throughout this process we will work with the other UK nations to support comparability across the UK.

Accountable Officer:

The Director General for Health and Social Care, working with the Directorate for Population Health, National Records for Scotland, PSD Scotland and Public Health Scotland, will be accountable for the implementation of the Scottish elements of this recommendation.