Have you even heard of Optum? You should have – it’s America’s biggest healthcare insurance corporation and it’s now analysing your NHS data: “We’ve been looking at the NHS data and we would say that once we have integrated data, although Optum is one of the largest health data companies in the world and has 190 million lives’ worth of data in the United States, what we have found in the UK puts that in the shade.”
Optum’s Chief Medical Officer explains why NHS data holds enormous value for one of the world’s largest healthcare data corporations
So now you know how much Optum wants your data, the next questions are: Who are Optum? Why does it want your NHS data? How are the UK’s health and social care systems being restructured to facilitate Optum’s capture of your data? What sort of power will that give to Optum over services provided to you? What can you do about it?
Who are Optum?
Optum is a subsidiary of UnitedHealth Group (UHG), which is currently ranked as the world’s 8th biggest company by revenue ($242 billion), making it bigger than pharmaceutical companies and banks. It has been implicated in multiple lawsuits including an action for fraud by the US Justice Department.
UHG is composed of two subsidiaries – UnitedHealthcare and Optum:
- UnitedHealthcare provides healthcare insurance primarily in the USA, but operates in more than 130 countries.
- Optum provides data analytics to healthcare provider organisations to risk-stratify patients (ie predicting which patients will be high-cost), cut costs of healthcare provision, and increase their revenue.
Optum is a big deal for one of the world’s largest corporations. It’s shown year-on-year growth of 11.1% since its incorporation ten years ago, and now comprises over 50% of UHG’s revenue. The British chief executive of Optum has recently been appointed as the CEO of UHG.
Why does Optum want your NHS data?
Remember that Optum’s parent company UHG is the USA’s biggest healthcare insurance corporation, its profits depend on reliably identifying high-risk patients and either increasing their insurance premiums or denying them care. There’s an intrinsic conflict in how UHG functions in the healthcare market, but the bottom line is that NHS data has enormous commercial value for modelling healthcare outcomes in an insurance system.
Optum is investing enormous resources in AI to build predictive healthcare models driven by Big Data. Heather Mickman – Optum’s VP of Platform Engineering – told the Devops Enterprise Summit that Optum sponsors 3500 college recruits to its Technology Program, has 7 mainframe computers and 100,000 server computers, holds 150 petabytes of data and spends $3.5 billion annually on technology and innovation.
Heather Mickman explained: “Accessing data reliably, consistently and in a known reusable way is our number 1 developer challenge because… UHG has grown significantly through acquisitions of… different source systems… across domains like… eligibility, claims, providers…”
Optum’s VP says it’s incredibly complex and costly to integrate data from the multiple different source systems it has acquired in the USA. This explains why the NHS’s comprehensive unified dataset is so attractive. Click To TweetIn the “Spark + AI” Summit, Jake Secor – Optum’s Senior Data Scientist – told an audience in Amsterdam that the bulk of advanced analytics at Optum is devoted to the “Disease Progression Model”. He gave the example of a long-term prediction model to forecast if patients with diabetes will develop complications such as limb amputation or visual loss and become “high-cost” in the following year, facilitating targeted intervention.
Jake Secor then made a key admission: “The problems here are it’s a little bit hard to tell when we are right and when we’re wrong…”. Optum’s ‘interventional’ model is complex to analyse computationally because if the predicted “high-risk” patient does not subsequently become high-cost in the following year, it’s difficult to tell if that’s due to the targeted intervention, or if the predictive model made a bad call.
In addition, Jake disclosed that Optum was relying on insurance claims data rather than clinical data: “The examples we gave here were all from (insurance) claims data… Because we’re a part of UHG, we do have access to all of UnitedHealthcare’s claims and we process a lot of claims for them daily… It’s a relatively clean dataset because claims are on standard forms… so we have a consistent stream of data coming in.”
In the same meeting, Optum’s AI Product Lead went on to explain that Optum needed more first-hand clinical data for predictive modelling, and that a key challenge was bringing all this data together. Josh Firminger, AI Product Lead: 'There’s obviously opportunities where Optum 'Greater’ is investing in acquiring some of this new data, but… How do we actually first bring it all together as we acquire these companies, and acquire their data…?' Click To Tweet
So there you have it. Unlike healthcare data in the USA, the NHS’s data is comprehensive, inclusive and relatively uniform over a population of 67 million people. It’s also directly acquired from patients rather than processed through insurance claims forms, and it includes world-leading genomic data on cancer and rare diseases.
The commercial value of NHS data to “feed” machine learning algorithms employed by UHG in its American insurance model is difficult to quantify. You might ask: Why isn’t Optum paying you big bucks for access to your data? Even more annoyingly: Why weren’t you even informed that America’s biggest insurance company is analysing your data?
How is your data being “integrated” to facilitate capture by Optum?
The UK’s national health and social care infrastructure is being fundamentally re-organised into Integrated Care Systems which are supposed to “join up” services provided by GP surgeries, hospital services, social care, and “other providers”. NHS England have set out “next steps” in this restructuring plan:
- Integrated Care Systems should be put on a clear statutory footing but with minimal legislative prescription,
- the membership of ICS boards should be “permissive”, and
- contracts awarded by ICS systems to providers of services should no longer be under oversight by the Competitive Market Authority, ie should no longer be required to go out for open competitive tender.
Integrated Care Systems will be significantly more complex than the previous Clinical Commissioning Groups (CCG) model provided by the Health and Social Care Act 2012 – not only will they have to join up multiple NHS Trusts and GP services, and also social care services provided by local councils and private care homes, but NHS England will also transfer responsibility for primary dental, ophthalmic and community pharmacy services to the ICS statutory body.
The critical building block for Integrated Care Systems is Optum’s concept of Population Health Management: “A new approach – called Population Health Management (PHM) – is helping us understand our current, and predict our future, health and care needs so we can take action in tailoring better care and support with individuals, design more joined up and sustainable health and care services, and make better use of public resources…..PHM is the critical building block for integrated care systems….”
Optum UK clearly states on its website that it now acts as NHS England’s National Development Partner for Population Health Management, and that it intends to leverage “expertise” running American healthcare systems to transform the NHS:
- “As NHS England and NHS Improvement’s National Development Partner for Population Health Management, we have worked with systems across the UK to develop the necessary infrastructure, intelligence and interventions that have delivered real impact.”
- “We leverage our expertise running data-driven, risk-bearing primary care networks in the USA to support Integrated Care Systems with the tools and transformation support that can ultimately improve quality and outcomes for the patient and value and experience for the provider.” Optum now acts as NHS England's National Development Partner, and clearly states its intention to leverage 'expertise' running American healthcare systems to transform the NHS. The direction of travel is clear. Click To Tweet
From a democratic perspective, it’s important to understand that NHS England and Optum have already started rolling out integrated care on the ground – Parliament is passing the Health and Care Act to rubber stamp what NHSE/Optum have already decided to do with your data. “Minimal legislative prescription” means government ministers can escape Parliament’s democratic scrutiny by using regulations and statutory instruments to share your personal data.
This includes a plan to target disabled people by sharing their data with the Department of Work and Pensions. In this Kafkaesque political project, the government will “support… disabled people and people with health conditions to enter or to stay in work” by providing their personal NHS data to the DWP. Given that the DWP is implicated in multiple suicides by people with disabilities, this will damage the doctor-patient relationship.
GP data is being handed to Optum – without your consent
GP practices have already clearly stated that they are handing your data over to Optum, they do not need your consent and you cannot opt out because the data is being processed “for the individuals’ care”. This is how the process works:
- GP data is handed over to the Clinical Commissioning Group (nb CCGs will be abolished shortly and replaced by ICSs),
- the CCG then pseudonymises the data and gives it to Optum to analyse,
- Optum then provides its recommendations regarding which patients might benefit from interventions,
- Optum then destroys its own copy of the data after analysing it,
- the GPs are then able to identify individuals from the pseudonymised data who Optum recommend for intervention.
- Even if Optum is destroying this data after analysing it, does it improve its own AI algorithms by “learning” from the data, and what will be the commercial benefit and wider applications of these algorithms? If Optum is deriving commercial benefit from your data, beyond “the individuals’ care”, then do they need your consent for this?
- There’s a well-known problem with AI-driven ‘black box’ machine learning models regarding the opacity of how the black box is processing the data – Essentially, how will GPs know that Optum’s analysis of their data is sound, or are they going to be put in a situation where they’re blindly following what Optum tells them to do?
Optum’s role in the allocation of your NHS and care services
Under a series of changes which culminated in the Health and Social Care Act 2012, an NHS internal market was promoted by the “purchaser-provider split”, ie splitting the NHS into those who commission or buy services (eg Clinical Commissioning Groups) and those who provide services.
Recent media “exposure” has focused on privatisation of service providers (Virgin, Operose, Centene etc) but has ignored the more fundamental question of corporate influence over the commissioning process (for instance, by Commissioning Support Units). Optum’s control over data analytics for Population Health Management will hand UHG enormous influence over commissioning of services throughout England.
The heart of the NHS “integration” is the same “population health” data-mining technology which is being used by UHG to power its insurance models in the USA. These AI algorithms will be used to analyse datasets for all services within the ICS, interpret that highly complex data, and then integrate those services.
Inevitably in the newly formed complex ICS systems, Optum’s predictive computer analytics will be indispensable for commissioning services, as well as reconfiguring future services, throughout the entire health and social care infrastructure of the ICS.
To understand the influence this will give to Optum in your daily lives, it’s worth looking at what Optum did to “integrate care” in Chorley. Optum determined “frailty” as a key target for NHS intervention in Chorley, and identified frail people by mining local council data for people who needed assistance with bin collections. Optum then targeted those people proactively for intervention.
Is this “necessary” for healthcare provision? How does it change the doctor-patient relationship, if Optum monitors bin collections of local residents and NHS England then proactively seeks out frail patients without prior consent? Is this consistent with medical ethics? Is this even legal? How does it change the doctor-patient relationship if Optum monitors bin collections of local residents and directs GPs to seek out frail patients? Is this consistent with medical ethics? Is this even legal? Click To Tweet
Optum’s co-optation of NHS policy-makers
Optum is firmly embedded in the executive leadership of the NHS. It has acted as the Gold Sponsor for the Leaders in Healthcare Conference, which has featured some of the NHS’s most influential leaders, including NHS England’s National Medical Director.
Collectively over 2018, 2019 and 2020, NHS England paid Optum £17 million for training. Since 2019, NHS England has hired Optum to lead a national Population Health Management Programme, training “leaders” across the NHS.
Optum Alliance (Optum and PwC) has been selected as a “preferred supplier” to deliver intensive national programmes to train NHS leaders in developing the new integrated care systems (the “Supporting Aspiring ICSs programme”) and in developing the “commissioning capability” for the new system which will manage NHS resources through Population Health Management.
Buckinghamshire, Oxfordshire & Berkshire West’s Integrated Care System states that Optum is funded by NHS England to train leaders to implement PHM and ICS systems:
“Population Health Management (PHM) Development Programme, an intensive 22-week programme supported by Optum and funded by NHS England and NHS Improvement (NHSE/I). The programme enables health and care systems to make rapid progress in developing PHM capabilities through data-led, proactive care projects that deliver improved outcomes for people. It is a structured programme designed to accelerate Integrated Care System (ICS) development across the key PHM domains: ‘Infrastructure’, ‘Intelligence’, and ‘Interventions’.”
The National Clinical Advisor for Primary Care with the NHS England transformation team, hired by NHS England in 2018, sits on the board of Dorset CCG which was one of the PHM wave 1 sites.
More recently she has acted as NHS England’s National Clinical Advisor for Population Health Management, and for the last 7 months has been a partner in Deloitte.
In 2020 she co-wrote an article with Optum’s Chief Medical Officer which praised Optum’s programme in Dorset, and demonstrated their shared vision for population health management in the NHS, including personalised care budgets. For all intents and purposes, NHS England and America’s biggest healthcare insurance corporation are acting as one.
What can you do about it?
Given that (i) Optum is NHS England’s National Partner in developing Population Health Management, (ii) it has trained NHS leaders throughout the UK in applying its own PHM algorithms, (iii) integrating NHS primary care, hospitals and social care for multiple providers requires highly complex computer modelling, and (iv) the 2022 Health and Care Bill will waive regulation by the Competitive Market Authority, Optum may effectively have a monopoly over the data-driven reorganisation and commissioning of health and social care services throughout the UK.
It should worry you (it worries me!) that your data is being processed by a healthcare insurance corporation because an insurance model relies on denying care to make a profit. Nobel prize-winners in Economics have explained that applying this model to healthcare is “inescapably inefficient, even in terms of the narrow logic of market allocation”.
This isn’t a theoretical risk. We already know that in 2020, NHS England paid Optum £7 million to identify high-cost patients in the NHS. Do you want to be identified as “high-cost” in the future?
The first thing to understand is this is YOUR data, and data is power. This is about YOU and YOUR RIGHTS, so make some noise by contacting your MP and your local councillors. But is there anything else we can do?
Well, Optum is currently harvesting your NHS data in pseudonymised form, without your consent, and NHS providers claim this is permitted under Article 9 (h) of the UK GDPR because it’s “necessary” for the provision of health or social care. However, if it can be shown that Optum’s machine learning algorithm is “learning” from your data, then – even if Optum deletes the data after processing it – can we argue that Optum is commercially exploiting your data in a way which requires your consent?
In addition, Articles 13 and 14 of the UK GDPR provide that data controllers must inform “data subjects” (that’s all of you!) if they process your personal data, and about the purposes of this processing. Do you feel informed about what’s going on? Can we legally challenge the paucity of information provided to you by the British Government, NHS England, local councils, Integrated Care Systems or Optum?
These are big questions and they have big implications for every one of us. With your help, and with a crack legal team, we intend to challenge exploitation of NHS data by America’s biggest healthcare insurance corporation. Please donate to our legal campaign, all your donations go to legal costs.
Also, remember – this is YOUR data and it’s powerful – so make some noise and sign our petition for Parliament to debate NHS data sharing agreements with American’s biggest healthcare insurance corporation. If NHSE/Optum are improving quality and outcomes for patients, then they should have no hesitation in opening themselves up to public scrutiny.