Under the Equality Act 2010, organisations have a legal duty to make changes, called reasonable adjustments, which are designed to ensure services are as accessible to people with disabilities or impairments as for everyone else. This is because, without such specific adjustments being made, people with disabilities may not have equal access to care and services.  

A ’Reasonable Adjustment Digital Flag’ has been built into the NHS Spine. This will enable health and care professionals to record and share, and view, details of reasonable adjustments, when they exist, wherever the person is treated across the NHS. This flag should include details of their significant impairments, underlying conditions, and key adjustments that should be considered.

The flag aims to enable: 

• Identification of all patients for who Reasonable Adjustment may be required
• Identification and sharing of key adjustments that will assist such patients to access care and help to ensure their consultations go well
• Consistent visibility and structure of this information for all those providing care.
• Maintenance of the information recorded and shared via the Digital Flag

Summary: checklist of actions for practices

• Develop a policy which is in line with the Reasonable Adjustment Digital Flag process and amend any other policies affected by this
• Agree a comprehensive approach to identifying disabled people with reasonable adjustment requirements including the new patient process in line with the Reasonable Adjustment Digital Flag process
• Establish a clear process for recording individuals’ disability and reasonable adjustment information in line with the Reasonable Adjustment Digital Flag process
• Create and establish a Reasonable Adjustment Flag in local patient record systems, to highlight and make individuals’ disability and reasonable adjustment information highly visible to staff
• Establish a clear process for sharing individual’s disability and reasonable adjustment information in line with the Reasonable Adjustment Digital Flag information
• Establish a clear process for reviewing and updating information on the individual’s records relating to disability and reasonable adjustment information
• Provide training and briefings to staff to explain the Reasonable Adjustment Digital Flag process, detail practice policies to be followed and raise awareness of support which staff can provide themselves.  National training for frontline staff via a short e-learning module is available at elfh. 

How can practices identify patients with a disability or significant impairment?

Under the Equality Act 2010 this is defined as a physical or mental impairment that has a substantial and long term (that is, greater than 12 months) negative effect on a person’s ability to undertake normal daily activities. 

• Disability and reasonable adjustment section on all new patient forms/registration documents (for example, add a standard line “do you require reasonable adjustments?”)
• Disability and reasonable adjustment section on recall, review and appointment letters (for example, add a standard line “do you require reasonable adjustments?”)
• Check at first contact
• Identification during standard health checks such as annual health checks, long-term condition reviews or during programmes such as seasonal immunisation campaigns
• Opportunistically: at any contact with the practice
• Identification through information received in from outside the practice such as referral letters, discharge or out-patient letters, community assessments
• Review of patient registers or consideration of cohorts coded with conditions which might result in impairment, such as those with conditions resulting in vision or hearing impairment
• Enable and encourage self-identification and optimise awareness (for example, via posters and practice website information)

Recording of information

Ideally this information should be recoded digitally, using the following SNOMED codes: 

Essential codes (must be added):

1. impairment with substantial and long-term adverse effect on normal day to day activity (Equality Act (2010) 1326341000000105

2. requires reasonable adjustment for health and care access (Equality Act 2010) 1108111000000107

3. consent code:

• consent given to upload data to Reasonable Adjustment Digital Flag (finding) 1853771000000105 or
• declined consent to upload data to Reasonable Adjustment Digital Flag (finding) 1853781000000107.

Consent

Consent is needed in the normal way to share the RADF on the NHS Spine; there is a dissent code noted above. In some cases, a capacity assessment and/or a best interests decision will need to be made. 

e-Learning

There is an e-learning programme on the NHS England elfh Hub regarding the RADF but members will need to be able to access the Learning Hub.

Health Passport

The contents of a Health Passport are likely to include all the information needed to complete a Reasonable Adjustment Flag; the existence of a Health Passport isn’t a substitute for recoding information on the RADF.

Further information about Health Passports is available on the NHS England website.

CQC

The CQC’s current guidance advice refers to the Accessible Information Standard; this was a forerunner to RADF and underpins the aim of identifying patients who would benefit from additional information and communication adjustments to assist their access to health services and facilitate their consultations.

CQC will undoubtedly wish to update their guidance to include specific references to the RADF, and Inspections include an assessment of this in terms of practice policies and implementation.  

GMC Good Medical Practice (GMP)

GMC Good Medical Practice was updated in January 2024, and there are a number of references to ‘reasonable adjustments’, at para 33, 65 and 70 that clearly directs participation with the RADF programme.