Dear Karen,
We have independently reviewed the actions that NHS Education for Scotland, and its successor organisation, Public Services Delivery (PSD) Scotland, have taken to address the six requirements set out in our October 2025 assessment of statistics about the NHS workforce in Scotland. On behalf of the Board of the UK Statistics Authority, I am pleased to confirm that they comply with the standards of Trustworthiness, Quality and Value in the Code of Practice for Statistics (the Code) and should be labelled as accredited official statistics. The detail supporting our judgement is included in the annex to this letter.
We are assured that PSD Scotland has taken appropriate initial actions to demonstrate its independence from Public Health Scotland. Your public commitment to produce your own statistical governance arrangements, consistent with the Code, within six months of PSD Scotland’s establishment will enhance this independence. We also welcome the introduction of regular reviews of pre-release access lists and the publication of a strategy which provides a public commitment to user engagement. We are confident in PSD Scotland’s plans to publish more information on cross-UK comparability and coherence, as well as its programme of work to improve the presentation of workforce statistics. We look forward to hearing about the development and outcomes of these work strands over the coming months.
This work demonstrates a clear commitment to upholding the standards of the Code. I would also like to thank your team for its open and constructive engagement throughout our assessment and for your ongoing commitment to improving these statistics.
I am copying this letter to Scott Heald, Head of Profession at Public Health Scotland, and Colin Tilley as Head of Programme and interim statistics lead in PSD Scotland.
Yours sincerely,
Ed Humpherson
Director General for OSR
Annex: Review of actions taken in response to OSR’s Assessment Report 400, ‘Statistics about the NHS workforce in Scotland’.
Requirement 1: To reinforce its autonomy from Public Health Scotland, NES should publish its own governance procedures and statistical policies.
Evidence from producer
NES (NHS Education for Scotland) developed and published its own revisions and statistical disclosure policies, as well as a new user engagement strategy (see Requirement 3 below). NES has also published information about its compliance with the Code of Practice and governance procedures, including information about the lead official role and its sponsor organisation (Public Health Scotland).
On 1 April 2026, NES merged with NHS National Services Scotland (NSS, which produces a small number of official statistics) to form PSD Scotland (which is already on the Official Statistics Order under its legal title, Common Services Agency).
Official statistics producers in NSS and NES will produce joint statistical governance arrangements that are consistent with the Code of Practice within six months of the establishment of Public Services Delivery (PSD) Scotland. NES has committed publicly to this plan and to providing an update on progress by the end of September 2026, both on its website and to OSR directly. Until then, PSD Scotland will use NES’s existing governance arrangements to cover NES’s publications and NSS’s existing governance arrangements to cover NSS’s publications. For example, the current lead official for NES will retain his lead official role for NES outputs.
OSR judgement
By developing and publishing policies which are clearly owned by the organisation and by publishing information about its statistical governance arrangements, PSD has demonstrated independence from PHS, its sponsor organisation. PSD continues to work closely with PHS, which provides support and guidance on issues as needed.
We are confident that PSD will meet the six-month timeline that it has set for itself to align policies and governance arrangements with the NSS side of the new organisation – PSD has committed to this publicly and agreed to report publicly and directly to us on progress. Based on this evidence, we have determined that PSD has fulfilled this requirement.
Requirement 2: To support the principle of equality of access and reduce the risk of data leaks, NES should review its PRA lists for all workforce statistics to ensure that all named officials still require access, particularly those in the Scottish Government. NES should also put in place a regular review process to ensure that PRA lists are minimised.
Evidence from producer
In September 2025, 105 people were given pre-release access (PRA) to the NHS workforce statistics. Following a review of the list, this was reduced to 76 people for the December 2025 release. Similarly, NES reduced the PRA list for its Child and Adolescent Mental Health Service (CAMHS) and psychology workforce statistics from 88 to 73 people between September and December 2025.
For each quarterly publication, the Health and Social Care Analytics team now reviews and confirms the PRA list for the Scottish Government and NHS boards.
NES hopes to further streamline the number of Scottish Government officials receiving PRA, working alongside a review into PRA practices that the Scottish Government recently carried out.
OSR judgement
It is good to see that NES has managed to reduce the size of its PRA lists following an initial review for its December 2025 publications.
The regular review processes that NES has now implemented, as well as its ongoing work with Scottish Government to further reduce the number of Scottish Government officials given PRA, mean that NES will continue to ensure that the lists are minimised and the risks associated with long PRA lists are reduced. Based on this evidence, we have determined that the requirement has been fulfilled.
Requirement 3: To strengthen confidence in the statistics and ensure user needs are met, NES should develop and publish a current user engagement strategy. This strategy should include information on how user requests are prioritised and clearly communicate what developments are being pursued, the rationale behind them, and, where applicable, the reasons for not progressing certain suggestions.
Evidence from producer
NES has published a user engagement strategy, which sets out what it wants to achieve with user engagement and how it will achieve this – including building capability to deliver effective engagement and strengthening an ongoing culture of engagement.
Since December 2025, NES has introduced quarterly newsletters, which provide stakeholders with an overview of current work and highlight new developments. The newsletters are sent directly to subscribed stakeholders and are also published on the NES website.
As part of its user engagement plan, NES will establish regular stakeholder engagement workshops on topics important to its users. This will allow it to understand the views of our users better and prioritise developments.
For example, engagement with the Primary Care Division of the Scottish Government resulted in a new set of official statistics in development on the progression of general practitioners, which were published in December 2025.
OSR judgement
We welcome NES’s published strategy, which provides a public commitment to user engagement.
The practical steps that NES has already taken to increase engagement opportunities, such as its quarterly newsletter and its plans to establish regular topic-based stakeholder workshops, will allow users to input into the development of NES’s statistics, to understand what developments are being undertaken and why, and to provide feedback on these plans. Based on this evidence, we have determined that the requirement has been fulfilled.
Requirement 4: To help users understand the comparability of the statistics and use them appropriately, NES should publish information about coherence and cross-UK comparability within its statistical releases. NES should also publish more information about any collaborative work being done to improve comparability across the UK.
Evidence from producer
NES has developed content about the comparability and coherence of workforce statistics, which it plans to publish as part of its June 2026 release. This new section of the annual report will be informed by, and include information about, NES’s participation in the UK Health Workforce Statistics Group. It will also include information about the differences between the four UK nations in terms of their institutional frameworks and published statistics, as well as the extent to which data are comparable between UK nations.
NES has publicly committed to publishing this new information in its Future Development Plan.
OSR judgement
While NES has not yet published this information on comparability and coherence, we are reassured by the plans that NES has shared with us that the content will address this requirement. We are also confident that NES/PSD will complete this action, based on its delivery against the other requirements and its public commitment to publishing this new information. Based on this evidence, we have determined that the requirement has been fulfilled.
Requirement 5: NES should improve the presentation of the statistics so that they are easy to access and use, engaging with users as part of this work. Where improvements are likely to take longer to implement or depend on wider developments, such as the planned new website, NES should include details of its plans on its future development page.
Evidence from producer
Since March 2026, the CAMHS and psychology dashboards have been enhanced following stakeholder feedback. Improvements include a clearer index and numbering of dashboard sections; clearer tabs allowing data to be viewed in either graphical or tabular format; the provision of additional retention data broken down by applied psychology training course and board of employment retention; and the publication of additional data on vacancies awaiting approval.
Subject to NES’s capacity, further work is due to start on additional enhancements, including a self-service option to allow users to produce bespoke tables.
NES is currently working on further developments to improve the presentation of the statistics. These include improved navigation of the website to reduce how many times users need to click to access the dashboards; this development is currently going through the testing phase. The statisticians at NES are also working with NES’s web design team to further improve navigation. This work will include a formal user engagement process, and is one of the commitments made in NES’s Future Development Plans.
OSR judgement
We are pleased to see the programme of work which NES/PSD has begun to improve the presentation of its statistics – it demonstrates NES’s commitment to continually improving the value of its statistics for users.
The changes to the dashboards, made in direct response to user feedback, have improved the user experience and addressed data gaps. NES’s commitment to improve the navigation of the website, work for which is already underway, will make the statistics more accessible and usable. We welcome NES’s inclusion of user engagement in this work via a survey as well. Based on this evidence, we have determined that the requirement has been fulfilled.
Requirement 6: Where data definitions differ from alternatives suggested by users, NES should clearly set out the reasons for the methods it has selected to ensure user confidence and understanding.
Evidence from producer
NES published the NHS and Primary Care Workforce in Scotland Technical Document, which contains detailed information about methods and definitions of statistics. In response to user questions about the definition of vacancies, this document has been updated to explain what vacancy data are collected for and to compare the definition of vacancies used in NHS Scotland with the definitions of vacancies used in other published statistics.
OSR judgement
NES’s new technical document brings information about data sources, data quality and methods into one place, in response to user feedback about difficulties finding this information previously. During our assessment, we noticed that users had different opinions to NES on definitions regarding vacancy data in particular. The new information that NES has added to its technical document on vacancies increases transparency and ensures that users can understand and have confidence in its methodological decisions. Based on this evidence, we have determined that the requirement has been fulfilled.
Related Links:Assessment of statistics about the NHS workforce in Scotland – Office for Statistics Regulation
