UPDATE: A new threshold of £100,000 for digital was introduced on 3 July 2013, with some exceptions. Read the letter from William Jordan, Director General at the Efficiency and Reform Group (ERG, Cabinet Office.
All money spent on digital services or digital projects by government must go through the Government Digital Service (GDS) approvals process.
And this section on spending controls, in the GDS service design manual, explains that GDS will examine and challenge all technology-related spending over a certain threshold and that no public commitment or expenditure should be made above these thresholds without prior approval.
For digital projects this threshold is zero.
This affects not just the Department of Health, but also all of our arm’s length bodies (ALBs), including the special health authorities.
Within the DH digital team we've been trying to unpick what this means for projects that are underway or are being planned at the Department of Health, as well as by our ALBs. We also need to understand how the digital spending controls relate to other Cabinet Office spending controls. For example, the advertising, marketing and communications controls process has a threshold of £100k, while ICT programmes have a threshold of £5million (other than for back office systems which have a threshold of £1million).
I wanted to get total clarity before communicating to all relevant parties, but as this is still an evolving area full clarity is proving rather tricky. So I’ve instead decided to share what we do know, as well as the questions that still remain.
What does ‘digital services’ mean?
The definition of ‘digital services’ includes what might also be called online transactional services. These are sometimes referred to by GDS as 'citizen-facing' services, but the wider definition (that we're going with) is external-facing transactions, including services aimed at businesses or other non-government organisations.
This wider definition reflects the scope of the management data that departments committed to providing as part of the Government Digital Strategy, and also with what is published in the transactions explorer tool. We expect the remit to exclude government to government transactions (including local government) and therefore believe this excludes Government to NHS and NHS to NHS transactions as well.
Note: there isn’t any DH data in the transactions explorer currently but we’re in the process of gathering and verifying some for the next quarter.
Examples of digital services within health and care
An example of an existing citizen-facing transaction that we think is included within the digital spending controls is the European Health Insurance Card (EHIC), a service provided to citizens by the NHS Business Services Authority (NHS BSA). Another example is the Public Health England(PHE) purchase a Radon risk report transaction. From now on, if NHS BSA or PHE want to redevelop these applications they will need to go through the GDS approvals process.
An existing transaction that is external-facing but not aimed at the ‘citizen’ is the Care Quality Commission's GP registration facility. The audience for this is both NHS and private providers so we think this would also need to go through the GDS approvals process in future.
What else is included in the zero spend threshold?
Websites and mobile apps are currently listed under the advertising, marketing and communications controls which has a spend threshold of £100,000, but GDS have said they expect all digital activity to come through their digital controls.
Although this makes perfect sense to me for websites and apps, where there is existing policy from GDS on their creation, virtually all modern communications and engagement involves an element of ‘digital activity’. At DH much of this is free but we also use low cost tools and procure services like Govdelivery for our e-newsletters and CitizenSpace for our consultation platform. It is not currently clear within the published guidance whether these purchases would come under the zero spend threshold. We hope not, from a practical perspective, but we’re not sure and are waiting for confirmation from GDS.
With regard to the policy on websites, departmental Digital Leaders were last year asked to put forward sites that should be considered for exemption from the single government website, GOV.UK. Some health ALBs were granted an exemption for their organisational website or for specific campaign or transactional websites that met the exemption criteria, but all other websites are expected to transition on to GOV.UK.
So no more websites should be built by government departments or ALBs without an exemption from GOV.UK.
And with mobile apps, the government has also made its position clear, in that they can rarely be justified. The line is: “Stand-alone mobile apps will only be considered once the core web service works well on mobile devices, and if specifically agreed with the Cabinet Office”.
What we’re going to do next at DH
We’ve agreed with our ICT colleagues and GDS that the best way forward in the medium to long term is for DH to put together a forward look of all the digital and ICT contracts and projects being planned across health and care and share this with GDS so they can get involved where it is most helpful.
But in the meantime we’d request that if you’re at DH, or in one of our ALBs, with a digital project on the go, or know there is a contract that needs renewing, please get in touch with us early.
Once we’ve got the answers to some of the questions dotted around this blog post we will make sure that we inform everyone more formally of what is required and what the process will be.
If anyone has more questions, suggestions, or even better – answers – then please post them here, or drop me an email at firstname.lastname@example.org.