Outcomes, audits and registries

Throughout 2025 we continued to build on our ongoing engagement with a range of key initiatives to better understand the quality of care provided by the sector.

Work towards NHS England’s Outcomes and Registries Programme (ORP) continued to be a dominant feature of the landscape, and we expect it to continue as a major focus in years to come.

Areas that still require more attention in 2026 include:

• Information governance: Work with NHS England, Government, regulators and providers to ensure a clear legal basis for submitting all patient data, regardless of payor, and address sector concerns.
• Sector inclusion by design: Continue to influence the involvement of independent providers at the outset of new audits, so submission rules do not unintentionally exclude them from contributing to or accessing insights.
• Data visibility for providers: Alongside building submission routFpes, ensure independent providers receive the same access to analysis and benchmarking insights as NHS organisations.

The existing Never Events Framework will remain active while this new process is in development. While the number of never events relating to the treatment of NHS patients remains small, we continue to strive to reduce never events to zero.

The Outcomes and Registries Programme

We continued our close engagement with NHS England’s Outcomes and Registries Programme throughout 2025.

The programme is driving the development of a single, unified registry solution – the Outcome Registries Platform, and through it, initiatives such as the Medical Device Outcome Registry (MDOR). It will play a key role in fulfilling the recommendations of the Independent Medicine and Medical Device Safety Review (IMMDS) and the Paterson Inquiry.

We and our members remain strongly supportive of this programme and the benefits it will provide to detect and predict issues relating to patient safety, outcomes and preventing harm to future patients.

Independent providers are mandated to submit class 2b and 3 implantable devices for NHS patients to the MDOR. A considerable amount of information now flows from independent providers to the registry, mainly relating to NHS patients treated by the sector, but there is more to be done.

In our report last year, we highlighted the urgency of addressing outstanding information governance issues that relate to private patient activity. 2025 saw limited progress in this area, although pleasingly NHS England published general guidance at the beginning of 2026. Several key questions still need to be addressed in relation to specific submissions such as those to the MDOR.

While effort to date has focused on information flowing into the system, it is just as important that meaningful information will be made available back to providers so that they can take steps to improve patient care.

By the end of 2025, the following registries were contributing data directly to the MDOR: Breast and Cosmetic Implant Registry, National Joint Registry, Orthopaedic Trauma Registry, the National Registry of Hearing Implants and the National Vascular Registry.

Plans are in place for other registries to submit data directly into the MDOR during 2026, including the Pelvic Organ Prolapse and Stress Urinary Incontinence (POPSUI) Registry, the National Institute for Cardiovascular Outcomes Research (NICOR) and the National Vascular Registry.

The National Consultant Information Programme (NCIP), which allows a view of consultants’ scope of NHS practice, made progress during 2025 with access to the NCIP data by a small number of independent sector responsible officers. Feedback indicates that access to NCIP data supports the move to a more rounded view of scope of practice. As more patient-level data becomes available across all providers, the scope for greater insights across a range of specialties will develop.

Private Healthcare Information Network (PHIN)

Over recent years, there has been considerable progress in the amount of information submitted to PHIN about privately-funded inpatient care.

At the end of 2025, the Competition and Markets Authority (CMA) officially confirmed that PHIN had achieved its silver milestone in the delivery of the Private Healthcare Market Investigation Order. This follows achievement of the bronze milestone in 2024.

Essential elements to achieve the silver milestone included:

• Tools to help patients better understand what their experience might be
• Publication of information about volume, length of stay, adverse events and patient feedback by hospitals that account for 97% of all private hospital procedures
• Collection and publication of information relating to anaesthetic fees
• More information about consultant fees
• Tools for providers to better understand and improve their data.

We welcome the progress that has been made towards this goal. It follows considerable investment by providers both by developing internal systems to collect and submit information, and through the direct funding of PHIN itself.

The next milestone – gold – is due to be achieved by the end of June 2026. This will demonstrate that the sector is fully compliant with the CMA Order.

The Acute Data Alignment Project (ADAPt)

PHIN, together with NHS England, has also been leading the Acute Data Alignment Project (ADAPt). ADAPt was originally conceived in 2018 to:

• Promote the completeness of patient records across NHS and private care
• Improve the visibility of patient data relating to healthcare quality, particularly where care is received across different providers
• Reduce the burden upon NHS trusts and independent healthcare providers in relation to data and reporting.

We have supported the principle of ADAPt from the point at which it was originally proposed. In 2022, three pilot studies were completed involving six independent providers and two NHS private patient units.

We, and our members, remain committed to the objectives of ADAPt but we are disappointed to report that little, if any, progress appears to have been made on ADAPt during 2025 and there is a lack of clarity on next steps