Ed Humpherson to Stephen Balchin: Publication of ad hoc statistics

Dear Stephen

Publication of ad hoc statistics

On 16 September you published information on the Distance travelled for a coronavirus (COVID-19) test in England: 1 September to 14 September 2020. This information had previously been referred to publicly by the Department without being published.

It is really positive that these data are now published – the publication of the data along with the basis for the calculation means the limitations are now clear and there is transparency around the figures. However, there are known limitations to the data, many of which have been highlighted by other organisations. For example, these data are based on direct distance rather than distance an individual would need to travel, and they do not include those who have decided not to take a test because the appointment offered was too far from their home.

We would like to see improvements to the data, responding to user needs. For example, it may be possible to draw on the data analytics within the Test and Trace programme to obtain some insight on people who are offered a test but do not take it up. However, we recognise the challenging environment in which your department is working, and that improvements would depend to some extent on the user interest in the Test and Trace Programme remaining high.

More broadly, in May 2020 we published a statement outlining our expectations around the production and use of management information by government and other official bodies. The statement highlights our view that when management information is used publicly to inform Parliament, the media and the public, it should be published in an accessible form, with appropriate explanations of context and sources. I hope that the publication of management information, when quoted publicly, becomes standard practice.

I am copying this letter to William Wragg MP, Chair of the Public Administration and Constitutional Affairs Select Committee.

Yours sincerely


Ed Humpherson

Director General for Regulation

Ed Humpherson to Stephen Balchin: NHS Test and Trace statistics (England)

Dear Stephen


Thank you for inviting my team to review your NHS Test and Trace statistics (England) publication. The pace of development of the programme and associated management information has been unprecedented. It is clear that providing these timely statistics is the result of a huge amount of work by individuals across a range of teams and organisations. We welcome the publication of these important data in an orderly release which demonstrates a commitment to the Code of Practice for Statistics.

Our rapid review has focused on the extent to which the statistics are produced and published in line with the expectations set out in the Code of Practice for Statistics. It is based primarily on publicly available information, supported by discussion with you and your team. It has not included a detailed investigation of the statistical methods or quality assurance processes supporting production of these statistics.

We appreciate the openness with which you and your team have engaged with the Office for Statistics Regulation (OSR) and your clear desire to constantly make improvements to the information available. Our review identifies areas we consider priorities for improvement over coming months.

Statistics on people tested for COVID-19 and subsequent contact tracing for those who test positive are essential for several purposes:

  1. to support understanding of the pandemic;
  2. to manage the test and trace programme;
  3. to inform the public about the implementation and effectiveness of the programme and enable them to hold government to account.

Without greater clarity on the purposes of this publication and clearer information on how data in this publication fit with other statistics or research outputs, this publication may not serve any of these three aims as well as it should. There are some key questions which the publication is not yet able to answer, such as the impact the programme has on reducing the spread of COVID-19. It is likely that the questions identified cannot all be answered solely through management information from the NHS Test and Trace Programme, but it is important that government seeks to better understand the effectiveness of the programme and its impact on the pandemic outcomes.

A summary of our findings is set out below, with further information provided as Annex A to this letter. We have also provided more detailed feedback to you directly.



The rapid development of these statistics and the improvements that have already been made in the five weeks since the first release should be commended. This first step in publishing information about testing and tracing is an approach that other countries within the UK can look to as they develop their own statistics.

The timeliness of statistics on the NHS Test and Trace Programme is an important part of their value but comes with inevitable trade-offs. More context and greater clarity on the purpose of the publication would enhance the value of these statistics.

A key purpose of the NHS Test and Trace (England) statistics must be to understand how effective the Test and Trace programme is. There are several important questions about the effectiveness of the programme that cannot be answered with the information currently available. In seeking to improve the publication we consider you should prioritise the provision of information which would help to answer these questions. For example: What proportion of those with COVID-19 are not covered by these statistics, perhaps because they are asymptomatic or have symptoms but do not choose to book a test? What is the journey time for an individual from experiencing symptoms to having their contacts advised to isolate? What is the impact of this time lag on the ability to reduce transmission of the virus? And what proportion of people asked go on to self-isolate? Further important questions we think the publication should seek to answer are outlined in Annex A.

There is a range of data on COVID-19 which has been rapidly developed and published. This leads to a confusing landscape. There needs to be greater clarity on the purpose of each publication and how they fit together. The Department of Health and Social Care should take a lead in helping individuals to navigate these data. Signposting readers to outputs that are likely to be of interest would also support navigation across different datasets. For example, the work you have done to improve the data on testing in the wider population (Pillar 2 data) has recently enabled extremely valuable data on the number of positive cases resulting from Pillar 1 and 2 tests by local authority to be added to the Coronavirus Beta Dashboard. It would be helpful to link to these data in the publication (as well as the methodology note which currently includes a link). It would also be helpful to link to the gov.uk Coronavirus Statistics and Analysis page.

You explained your approach to iteratively developing the publication in order to support timeliness and transparency, taking into account data availability and your assessment of the quality of these data. This means the content of the publication is constantly evolving. To maximise the value of the data in the bulletin and ensure it can be readily understood by the public, you should review the language used and continue your development of the ‘Main points’ section. A visualisation of the numbers as they flow through the system would support understanding of the end to end process. Two examples of ways other organisations have achieved this are provided in Annex B to this letter.


You have published a methodology note containing definitions for the many technical terms used throughout the bulletin, as well as a clear explanation of the complex test and trace process. This aids understanding of the statistics.

It would be helpful to provide further information to ensure data are used appropriately and limitations are well understood. For example, an indication of the scale of duplicates in the cases transferred to the contact tracing system would support users in understanding if the data are fit for their particular purpose.

To reassure users about the quality of these statistics, we encourage you to publish more information about your approach to quality assurance in line with the Government Statistical Service guidance on urgent quality assurance of data. This should cover quality assurance arrangements and how they reduce the risk of errors.


The publication of these statistics is well supported by publication of a Statement of compliance with the Code of Practice for Statistics. For example, this document clearly states that decisions about which data are published are taken independently and based on statistical judgments.

We are pleased to see that the statistics are being published on a regular weekly basis and would encourage the department to more formally pre-announce future publication dates.

You have also demonstrated good practice in your handling of revisions, which are clearly signposted and explained. In future releases we would like to see an indication of the size of revisions, so that users can understand their impact.

As set out in our rapid review guidance you can include a statement in your methodology note such as “These statistics have been produced quickly in response to developing world events. The Office for Statistics Regulation, on behalf of the UK Statistics Authority, has reviewed them against several key aspects of the Code of Practice for Statistics and regards them as consistent with the Code’s pillars of Trustworthiness, Quality and Value.”

We look forward to seeing these statistics continue to develop.

Yours sincerely


Ed Humpherson

Director General for Regulation

Response on NHS funding

Dear Ed

NHS Funding

Thank you for your letter of 24th September regarding the announcement made on 5th August 2019 on the provision of an additional £1.8 billion of capital funding for the NHS.

This is all “new” money for the NHS. The NHS capital budget was increased by £1.8bn and NHS capital expenditure can be £1.8bn higher as a result. I trust that the further detail below, including a brief description of government accounting rules, provides sufficient explanation of statements made by the Department for those who are keen to understand it in more detail.

Government Accounting Rules

Her Majesty’s Treasury sets out the spending limits for government departments on capital (CDEL) and resource (RDEL) in spending reviews. These limits generally cover a number of years; although they are routinely changed at budgets and through the in-year Estimates process. These controls limit how much is spent in each year. Cash that is held (for example in reserves) by public sector organisations such as NHS trusts does not score against these controls until it is spent. These national limits are not always delegated to local organisations. For example, the NHS operates as a devolved system with individual hospitals enjoying a large degree of discretion over their capital investment decisions, but the spending still counts against the national total.

Irrespective of the source of cash, aggregate capital expenditure across all NHS organisations must be managed within the national CDEL.

The Extra Funding

The announcement of £1.8 billion additional investment in the NHS resulted in a £1.8 billion increase in the Department of Health and Social Care’s (DHSC) capital expenditure limit (CDEL) across the current and subsequent financial years. The majority, £1.1 billion, of the increase is in the current year and comprises a £1 billion in-year boost to NHS operational capital and £100 million (out of a total of £850 million) for hospital upgrades. As a result CDEL in 2019-20 increases from £5.9bn to £7.0 bn . The increase is in DHSC’s CDEL (rather than these announcements being funded by a re-allocation of underspends from other CDEL budgets), so clearly represents ‘new money’; i.e. the DHSC is able to spend £1.1 billion more capital in 2019-20 than prior to the announcement and £0.7bn in subsequent years.

Some external challenge has reflected a conflation of local plans and the national CDEL limit. Capital expenditure is financed through a range of means. In some cases, Trusts are able to finance capital investment themselves through their own cash reserves (built up from surpluses on prior year trading). In other cases, finance can be provided by DHSC, including through Public Dividend Capital and loans.

However financed, the aggregate of NHS individual plans still has to fit within the national budget. The additional £1.1 billion CDEL provided in 2019-20, means that there was sufficient scope for DHSC to go ahead and approve emergency capital applications and PDC allocations as well as other nationally funded capital programmes, without it being necessary to ask trusts to constrain their own self-financed plans. It was in this context that the NHS Chief Financial Officer, Julian Kelly wrote to providers in August.

I hope this note answers your questions fully but if not please do come back to me.

Yours sincerely

Mark Svenson
Head of Profession for Statistics
Department of Health and Social Care


Related Links:

Ed Humpherson to Mark Svenson (September 2019)

Statements on NHS funding

Dear Mark

I am writing to you regarding the announcement made on 5th August 2019 on the provision of £1.8 billion funding for the NHS. This figure consisted of two distinct parts: £850 million of new funding to upgrade outdated facilities and equipment, and a £1 billion increase to NHS capital expenditure limits.

As I am sure you are aware there has been a significant level of debate as to whether the £1 billion increase in capital expenditure should be considered new resource or should be considered cash already held by Health trusts which they have now been given permission to spend as a result of increased limits on capital expenditure. However, further statements and responses from the Department of Health and Social Care (DHSC) do not seem to have fully answered these questions.

DHSC’s press release on 5th August stated that the whole £1.8 billion was new money, a claim that has been reiterated by Health Ministers. On 17th August, NHS Chief Financial Officer Julian Kelly wrote to NHS trusts informing them that the £1 billion increase in DHSC’s baseline capital expenditure limit means they can revert to their original capital plans which are funded by their own income and reserves.

Full Fact requested more information from DHSC on this matter, and on 29th August DHSC responded stating that “The NHS has an extra £1.8 billion of new funding to invest in projects, money which the NHS did not previously have to spend…This includes £850 million which will directly fund 20 new hospital upgrades—money that had not been previously allocated.”

So far, we have been unable to identify an authoritative official statement describing how the £1.8 billion is funded, and the mechanisms that led the £1 billion capital expenditure to be withheld and then subsequently released to trusts. I encourage DHSC to release such a statement as soon as possible in order to enhance transparency and support public understanding.

I am sure that you will agree that the relative complexity of the funding structures underpinning this announcement need to be carefully explained.

I am copying this letter to Full Fact.

Yours sincerely

Ed Humpherson
Director General for Regulation