Availability of real-time access to the mortality database

Joel Smalley made this Freedom of Information request to UK Statistics Authority This request has been closed to new correspondence. Contact us if you think it should be reopened.

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The request was successful.

Dear UK Statistics Authority,

The mortality data and analyses published by the ONS are fundamentally flawed because they are produced by the death registration date instead of the actual date that the death occurred. In past times, this may have been acceptable if the registration delay was consistent and relatively few deaths were referred to the coroner. Indeed, the ONS acknowledges this.

However, in the "COVID era", and particularly since the advent of the mass mRNA experiment, this is no longer the case. Fortunately, as a result of COVID, the ONS publishes just one somewhat useful, regular mortality dataset - "Death registrations and occurrences by local authority and health board". However, even this is impoverished due to:

1. the delay in collecting/reporting deaths; and
2. the fact that it is not updated beyond six months after calendar year end.

Please respond to these two questions:

1. Do you acknowledge that the system for recording deaths in England & Wales is no longer fit for purpose and therefore agree to record deaths as they occur in a more timely manner? (Since most mortality datasets do not include cause of death, I do not see that coroner-referred deaths should present an issue in this regard.)

2. Do you acknowledge that to provide real-time access to the ONS mortality database is in the best interests of both the ONS (in terms of reducing administrative burden) and the public (in terms of making public data more readily accessible) and therefore agree to recommend that the ONS prioritises the availability of such an interface instead of ad hoc data dumps?

Yours faithfully,

Joel Smalley

Dear Joel,

Thank you for your email.

We have discussed your below concerns with our regulatory body the Office for Statistical Regulation. They are going to handle and treat the below as a case study and will be in contact with you as soon as possible to discuss your concerns.

In order for them to do this can I please check that you give consent for me to provide them with your email address and name? Please provide me with the best contact details and I will forward them onto OSR.

Many thanks

Kera

The Freedom of Information Team | UK Statistics Authority | Awdurdod Ystadegau'r Deyrnas Unedig
@UKStatsAuth | [email address] | http://www.statisticsauthority.gov.uk

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Dear FOI Team,

Yes, please share my details. Thank you for your prompt response.

Yours sincerely,

Joel Smalley

Dear Mr Smalley,

Thanks for your patience while we investigated this issue. We plan to
issue our response this week. As we are corresponding with an email which
will publish our response on What do they know we will also publish our
response on our website.

We’ll be back in touch with further information shortly.

Kind regards,

Chris

[email address]

Office for Statistics Regulation | UK Statistics Authority

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Dear Mr Smalley

Thank you for contacting the UK Statistics Authority with your concerns
about the methodology used in mortality publications published by the
Office for National Statistics. I am writing to you from the Office for
Statistics Regulation (OSR), the independent regulatory arm of the UK
Statistics Authority. At OSR, we don’t publish statistics ourselves and
are separate from the ONS.

We have looked into the methodology used in ONS’s mortality publications.
You are correct to say that all ONS mortality publications use the date
that the death is registered, not the date that the death has occurred. We
have spoken to ONS about the reasons for this, and they are as follows:

Death Registrations

Firstly, by way of background: for a death to be registered, the cause of
death must be determined. In the majority of cases, this is done by a
doctor, who will have seen the individual in the last two weeks of their
life. At present, 74% of deaths in England and Wales are registered by
doctors. The remaining deaths are registered with a coroner. Registration
by a coroner typically takes place if the cause or the circumstance of
death is uncertain, with a post-mortem sometimes being used to determine
cause of death. As such, deaths registered by coroners are more likely to
be subject to registration delays than those registered by doctors.

You are right to say that registration delays increased in 2020, as a
result of the pandemic. This happened for two reasons. Firstly, there were
more deaths than average in 2020, caused by COVID-19. Secondly, there were
delays in coroner-registered deaths. This meant that in 2020, the median
time between death occurring and death registration increased from four
days in 2019 to 5 days in 2020. ONS has not yet published its analysis of
registration delays for 2021, but Coroners statistics for 2021 indicate
that the number of deaths registered by a coroner dropped to the lowest
number since 1995.

Deaths resulting from COVID-19 are some of the least likely causes of
deaths to be subject to registration delays, with the majority of these
deaths being registered within one week in 2020 (86.5%). The rapid
reporting of deaths due to COVID-19 occurred because there was a specific
need for this data, as an early indicator of deaths during the pandemic.
The diagnostic criteria for a death resulting from COVID-19 (a positive
test within a number of days of the death) also allowed for a low level of
registration delays.

As indicated in an analysis by ONS, deaths that are most often subject to
registration delays are those resulting from external causes (ICD-10
chapter 20). Deaths in this category include suicide and drug and alcohol
related deaths. Registrations of deaths from these causes may take months
or years to be registered, particularly if an inquest is required.

Date of Recording and Date of Occurrence

At present ONS publishes mortality data by the date that the death is
registered. When a death is recorded, the General Register Office (GRO)
sends information on the date of registration and the date of death. All
cases have a date of recording and the majority have a date of occurrence
as well. However, in some cases the date of occurrence is missing, such as
cases when the exact date of occurrence is unknown.

The primary reason for ONS publishing data using the date the death is
registered is that it allows for the creation of a static mortality
dataset that is comparable over time. If the date of death was to be used,
historic mortality publications would need to be updated whenever a new
death is registered. If mortality delays are considered, this would mean
that some mortality publications would continue to be updated for
potentially over a year after the date of death. Using the date of
registration mitigates this issue. It ensures that data are complete for a
given time period.

ONS does not receive notification of a death until it is registered with
the GRO. Because of this, it would not be possible for ONS to publish
real-time data as you suggested in your email.

Our view

Prior to the pandemic, ONS produced a series of mortality publications on
a regular basis. ONS has since increased the number of regular
publications on deaths, as well as publishing ad hoc publications when
needed. We are satisfied that these publications meet the needs of users
of these statistics. We have attached a table below with a breakdown of
mortality publications.

As a result of the COVID-19 pandemic, we have seen an increase in interest
about statistics on mortality. Because of this, we have been conducting a
Compliance Check on ONS’s mortality statistics, focusing on compliance
with the Quality pillar of our Code of Practice for Statistics. We are
aiming to publish the findings of this review in early December 2022. As
part of our Compliance Check, we will be asking ONS to make clear some of
the reasons for the current methodology, such as its decision to publish
data by the date the death was registered, not the date that the death
occurred.

Thank you again for contacting us about this issue and also for your
patience as we have investigated your concerns.

Yours sincerely,

Ed Humpherson

Sent on behalf of Ed Humpherson, Director General for Regulation

Chris Ferrier

Office for Statistics Regulation | UK Statistics Authority

[1]@StatsRegulation | [2]osr.statisticsauthority.gov.uk | [3]Privacy
Policy

Sources of Mortality Data

┌────────────────┬────────────────┬─────────────┬─────────────┐
│Dataset   │Details  │Cause of │Timeliness   │
│ │ │death/Covid │ │
│ │ │details   │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[4]Death │Provisional │Includes │Uses date of │
│registrations │counts of the │cause of │registration,│
│and occurrences │number of deaths│death (Covid │not date of │
│by local │registered in │only)  │death  │
│authority and │England and │ │ │
│health board  │Wales, including│  │  │
│ │deaths involving│ │ │
│  │coronavirus │Published │ │
│ │(COVID-19), by │from April │ │
│ │local authority,│2020 │ │
│ │health board and│onwards   │ │
│ │place of death │ │ │
│ │in the latest │ │ │
│ │weeks for which │ │ │
│ │data are │ │ │
│ │available  │ │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[5]Deaths │Provisional │Includes │Uses date of │
│registered │counts of the │cause of │registration,│
│weekly in │number of deaths│death (Covid │not date of │
│England and │registered in │only)  │death  │
│Wales, │England and │ │ │
│provisional  │Wales, by age, │  │  │
│ │sex and region, │ │ │
│  │in the latest │Was published│ │
│ │weeks for which │pre-Covid │ │
│ │data are │19  │ │
│ │available. │ │ │
│ │Includes the │  │ │
│ │most up-to-date │ │ │
│ │figures │ │ │
│ │available for │ │ │
│ │deaths involving│ │ │
│ │coronavirus │ │ │
│ │(COVID-19).  │ │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[6]Deaths │Number of deaths│Doesn’t │Uses date of │
│registered │registered each │include cause│registration,│
│monthly in │month by area of│of death   │not date of │
│England and │usual residence │ │death   │
│Wales  │for England and │  │ │
│ │Wales, by │ │ │
│ │region, county, │Was published│ │
│ │local and │pre-Covid │ │
│ │unitary │19   │ │
│ │authority, and │ │ │
│ │London │ │ │
│ │borough.  │ │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[7]Monthly │Provisional │Includes │Uses date of │
│mortality │death │cause of │registration,│
│analysis, │registration │death   │not date of │
│England and │data for England│ │death  │
│Wales  │and Wales, │  │ │
│ │broken down by │ │ │
│ │sex, age and │Was published│ │
│ │country. │pre-Covid 19.│ │
│ │Includes deaths │Contains │ │
│ │due to │information │ │
│ │coronavirus │on Covid-19 │ │
│ │(COVID-19) and │deaths   │ │
│ │leading causes │ │ │
│ │of death.  │  │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[8]Deaths due to│Provisional │Includes │Uses date of │
│COVID-19 by │age-standardised│cause of │registration,│
│English region │mortality rates │death (Covid │not date of │
│and Welsh health│for deaths due │only)  │death  │
│board  │to COVID-19 by │ │ │
│ │sex, English │  │ │
│ │regions and │ │ │
│ │Welsh health │Published │ │
│ │boards.  │from March │ │
│ │ │2020 │ │
│ │ │onwards   │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[9]Deaths due to│Provisional │Includes │Uses date of │
│COVID-19 by │age-standardised│cause of │registration,│
│local area and │mortality rates │death (Covid │not date of │
│deprivation  │for deaths due │only)  │death  │
│ │to COVID-19 by │ │ │
│ │sex, local │  │  │
│ │authority and │ │ │
│ │deprivation │Published │Discontinued │
│ │indices, and │from November│– as deaths │
│ │numbers of │2020 │by Covid-19 │
│ │deaths by │onwards  │decreased, │
│ │middle-layer │ │some │
│ │super output │ │geographical │
│ │area.  │ │areas had low│
│ │ │ │numbers   │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[10]Deaths │Provisional │Includes │Uses date of │
│involving │age-standardised│cause of │registration,│
│COVID-19 by │mortality rates │death (Covid │not date of │
│month of │for deaths │only)  │death  │
│registration, │involving │ │ │
│UK  │COVID-19 by sex │  │  │
│ │and month of │ │ │
│ │death │Published │ │
│ │registration, │from March │ │
│ │for England, │2020 │ │
│ │Wales, Scotland,│onwards  │ │
│ │and Northern │ │ │
│ │Ireland.  │ │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[11]Pre-existing│Pre-existing │Includes │Uses date of │
│conditions of │conditions of │cause of │registration,│
│people who died │people who died │death (Covid │not date of │
│due to COVID-19,│due to COVID-19,│and │death  │
│England and │broken down by │pre-existing │ │
│Wales  │country, broad │conditions)  │  │
│ │age group, and │ │ │
│ │place of death │  │ │
│ │occurrence, │ │ │
│ │usual residents │Published │ │
│ │of England and │from January │ │
│ │Wales.  │2021 │ │
│ │ │onwards  │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│[12]Single year │Provisional │Includes │Uses date of │
│of age and │deaths │cause of │registration,│
│average age of │registration │death (Covid │not date of │
│death of people │data for single │only)  │death  │
│whose death was │year of age and │ │ │
│due to or │average age of │  │  │
│involved │death (median │ │ │
│COVID-19  │and mean) of │Published │ │
│ │persons whose │from │ │
│ │death involved │September │ │
│ │coronavirus │2021 │ │
│ │(COVID-19), │onwards   │ │
│ │England and │ │ │
│ │Wales. Includes │ │ │
│ │deaths due to │ │ │
│ │COVID-19 and │ │ │
│ │breakdowns by │ │ │
│ │sex.  │ │ │
├────────────────┼────────────────┼─────────────┼─────────────┤
│UKHSA: │Data used in the│Includes │Uses death │
│[13]Coronavirus │dashboard comes │cause of │registration │
│in the UK │from four │death (Covid │data, but │
│dashboard   │sources:   │only)  │data can be │
│ │ │ │ordered by │
│ │NHS England: │  │date of │
│ │deaths are │ │death.   │
│ │reported to │Published │ │
│ │trusts using the│from March │  │
│ │[14]COVID-19 │2020 │ │
│ │Patient │onwards   │ │
│ │Notification │ │ │
│ │System (CRNS)  │  │ │
│ │ │ │ │
│ │  │ │ │
│ │ │ │ │
│ │UKHSA Health │ │ │
│ │Protection Teams│ │ │
│ │(mostly for │ │ │
│ │deaths not in │ │ │
│ │hospitals)  │ │ │
│ │ │ │ │
│ │  │ │ │
│ │ │ │ │
│ │Linking data on │ │ │
│ │confirmed │ │ │
│ │positive cases –│ │ │
│ │when a patient │ │ │
│ │dies, the NHS │ │ │
│ │central register│ │ │
│ │of patients is │ │ │
│ │notified. The │ │ │
│ │list of │ │ │
│ │lab-confirmed │ │ │
│ │cases of │ │ │
│ │Covid-19 is │ │ │
│ │checked against │ │ │
│ │the central │ │ │
│ │register  │ │ │
│ │ │ │ │
│ │  │ │ │
│ │ │ │ │
│ │ONS’s death │ │ │
│ │registrations │ │ │
│ │(which come from│ │ │
│ │the GRO) can be │ │ │
│ │linked to a │ │ │
│ │lab-confirmed │ │ │
│ │Covid-19 test. │ │ │
│ │There is a │ │ │
│ │10-day lag.   │ │ │
│ │ │ │ │
│ │  │ │ │
└────────────────┴────────────────┴─────────────┴─────────────┘

From: DG Regulation <[email address]>
Sent: 06 December 2022 14:48
To: [FOI #911352 email]
Subject: Casework - Real time access to Mortality data

Dear Mr Smalley,

We’ll be back in touch with further information shortly.

Kind regards,

Chris

[15][email address]

Office for Statistics Regulation | UK Statistics Authority

[16]@StatsRegulation | [17]osr.statisticsauthority.gov.uk | [18]Privacy
Policy

For information on the work of the UK Statistics Authority, visit:
[19]http://www.statisticsauthority.gov.uk

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Dear DG Regulation,

Thank you for your reply.

Unfortunately, you have failed to address the two pertinent questions I raised.

1. You appear to be satisfied with the delays in recording and reporting data. You have come to this conclusion based on a 1-day average increase in registration delay for 2020 and the lowest recorded delays since 1995 for 2021. What about 2022? According to my analysis of 2022 data, there are substantial delays for all ages under 75, dating back to the end of 2021. What are the coroner statistics for 2022? Have you done your own analyses for 2022 that are independent of the coroner? Do they confirm that there is no increase in registration delays for 2022?

Furthermore, you are stating that it is the responsibility of the GRO to report deaths to you when registered without acknowledging that this delay poses a problem in terms of accurate mortality analysis. Does this mean, you are not interested in negotiating with the GRO for more timely release of death data, pending cause of death? Are you suggesting that the ONS analyses themselves cannot benefit from more timely data?

2. With respect to the use of registration date data, you have repeated information that is already published on your various reports regarding the benefit of having a static historical report. This may seem convenient in terms of not having to update historical reports but does not address the fundamental issue that all such reports are erroneous, i.e. incomplete, by that very omission. As new data becomes available, it could even change the entire outcome of a report. As a result of using registration date data, you not only ensure that historical reports remain erroneous in those circumstances, you also ensure that future reports are also erroneous since they will contain the updated registration data that actually belongs to a historical period. Rather than establishing a "complete" report as you suggest, you achieve quite the opposite as time goes by.

3. With regard to access to the real time database rather than the ONS acting as gatekeeper, you have stated that you are satisfied that the data published meets the needs of users but you have not explained how you came to this conclusion. Clearly, as a user, I have expressed that the reports do not meet my needs and I have explained why. Do you have a good explanation as to why filtered reports from the ONS should better meet the needs of all or any other users than access to the underlying data in a more timely and readily accessible format?

Yours sincerely,

Joel Smalley

Dear Joel,

Thank you for getting back in touch. I have passed your concerns to the team, and we'll respond to you more fully once they have considered them.

Kind regards,

Chris

[email address]
Office for Statistics Regulation | UK Statistics Authority
@StatsRegulation | osr.statisticsauthority.gov.uk | Privacy Policy

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Dear Mr Smalley,

Thank you for your response to our email.

We acknowledge that there are limitations caused by primarily reporting
deaths data by the date of occurrence, as opposed to date of death (most
of ONS’s publications report the date the death is reported, but the
[1]Monthly Mortality Analysis also reports the date of death). This method
of reporting is subject to the effects of registration delays (there are
often delays in recording deaths over bank holidays, or deaths recorded by
coroners). We do however appreciate the merits of keeping a static record
of mortality, as opposed to a dynamic dataset that constantly updates.
Because of this, we intend to engage with ONS to explore the ways in which
some of these limitations could be mitigated. This will be through the
Compliance Check we outlined in our previous email.

We would also like to acknowledge the steps taken by ONS to inform users
of the impacts of their focus on the date of registration rather than
occurrence, and the impact of registration delays on the data. In
addition, ONS conducts their own analysis of the [2]impacts of
registration delays on the data, and [3]provides data to allow users to
conduct their own analysis.

In response to our email, you outlined three questions. Our answers are as
follows:

1. The impact of registration delays on data from 2022: You have
conducted your own analysis which you claim shows ‘substantial
registration delays for all ages under 75, dating back to the end of
2021’. You ask whether we have conducted our own analysis of Coroners
data, and whether that analysis shows registration delays for 2022.

With regards to registration delays, we have based our conclusions on the
latest published official statistics. These show that [4]registration
delays did increase in 2020. [5]Coroners statistics for 2021 indicate that
the number of deaths registered by a coroner dropped to the lowest number
since 1995. ONS has not yet published its analysis of registration delays
for 2021, but it has [6]pre-announced the release of the analysis, coming
out in March or April 2023. The Coroners statistics for 2022 are also not
yet published. These are due to be published on [7]11 May 2023. A delay
between the year ending and the production of the annual report allows for
the analysis to be conducted and for quality assurance processes to be
completed. We have not and would not conduct our own analysis. As a
statistics regulator (rather than auditor), it is not appropriate for us
to conduct an analysis of data in advance of statistics being published.

2. Reporting deaths by the date of registration allows for the creation
of an incomplete record of mortality

As your email states, ONS have published various reports regarding the
benefit of using date of registration – primarily because it ensures that
data are complete for deaths registered in a given time period and allows
for comparisons over time. You are however correct in your assertion that
this results in an incomplete record of all deaths that occurred. This is
particularly apparent as deaths that are registered more than a year after
occurrence are not included in ONS’s weekly, monthly and annual mortality
publications. However, as these deaths tend to occur as a result of
external influences, they are usually covered in specific ONS
publications, such as those on [8]suicide, [9]drug-related deaths and
[10]alcohol-specific deaths.

We acknowledge that both methodologies have their limitations. However, we
feel it is important here to acknowledge the steps taken by ONS to explain
the reasons for their chosen methodology, and to provide users with
sufficient data and statistics to mitigate these issues, such as the
provision of data on the date of death in the Monthly Mortality analysis,
and the publication of statistics assessing the impact of mortality
delays.

3. ONS meeting the needs of users: You have asked how we can be
satisfied that ONS has met the needs of their users when you, as a user,
do not feel that your needs are met.

While we do encourage producers to meet the needs of their users, we
recognise that this will not always be possible. As stated in my previous
email, ONS does not have access to real-time data and therefore is unable
to meet the user need that you have identified.

ONS previously reported the number of deaths occurring in a time period,
which meant that a period of time had to lapse before the analysis could
take place. This process was impacted by registration delays and as a
result, in 2006 ONS changed their methodology to their current method of
reporting on death registration. At the time of the change, this resulted
in a significant improvement, as it allowed for a much more timely release
of the data. ONS conducted a [11]user consultation in 2007 to determine
which methodology would best suit their users.

It is not possible for ONS to receive mortality data from the General
Register Office at an earlier date. Once a death occurs, a death
certificate is issued by either a GP, a doctor or a coroner. The death
certificate is then sent to the Local Registrar by email or post.

The Local Registrar manually enters the data into the online registration
system. The data are then received by the GRO. From here, the data are
transferred to ONS. Neither the GRO nor the ONS are made aware of a death
until after the death is formally registered with the Local Registrar.
This process works well for deaths registered by doctors, but it does mean
that delays are present with coroner registered deaths.

NHS Digital have published a [12]Mortality Data Review, which describes
the death registration process in detail. The flowchart on page five of
the document details the steps involved in the statutory reporting
process, and highlights areas where delays are likely to occur.

Overall, ONS has increased the number of regular publications on deaths,
as well as ad hoc publications when needed. We are continuing to conduct a
Compliance Check on ONS’s mortality statistics, focusing on compliance
with the Quality pillar of our Code of Practice for Statistics. We are
aiming to publish the findings of this review in early 2023 and would be
happy to send the findings of this review to you when it is published,
should that be of interest.

Yours sincerely

Ed Humpherson

Sent on behalf of Ed Humpherson, Director General for Regulation

Chris

Office for Statistics Regulation | UK Statistics Authority

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Dear Mr Smalley,

I would like to apologise. Following Ed Humpherson’s email to you on 30
January 2023 we noticed that there was a small error in our email on the
second paragraph. Specifically we changed the following sentence,
highlighting in bold the words we changed:

Please find a corrected email in full below.

Kind Regards,

Kirsty

Kirsty Garratt

Office for Statistics Regulation | UK Statistics Authority

[2]@StatsRegulation | [3]osr.statisticsauthority.gov.uk | [4]Privacy
Policy

Dear Mr Smalley,

Thank you for your response to our email.

We acknowledge that there are limitations caused by primarily reporting
deaths data by the date of registration, as opposed to date of death (most
of ONS’s publications report the date the death is registered, but the
[5]Monthly Mortality Analysis also reports the date of death). This method
of reporting is subject to the effects of registration delays (there are
often delays in recording deaths over bank holidays, or deaths recorded by
coroners). We do however appreciate the merits of keeping a static record
of mortality, as opposed to a dynamic dataset that constantly updates.
Because of this, we intend to engage with ONS to explore the ways in which
some of these limitations could be mitigated. This will be through the
Compliance Check we outlined in our previous email.

We would also like to acknowledge the steps taken by ONS to inform users
of the impacts of their focus on the date of registration rather than
occurrence, and the impact of registration delays on the data. In
addition, ONS conducts their own analysis of the [6]impacts of
registration delays on the data, and [7]provides data to allow users to
conduct their own analysis.

In response to our email, you outlined three questions. Our answers are as
follows:

With regards to registration delays, we have based our conclusions on the
latest published official statistics. These show that [8]registration
delays did increase in 2020. [9]Coroners statistics for 2021 indicate that
the number of deaths registered by a coroner dropped to the lowest number
since 1995. ONS has not yet published its analysis of registration delays
for 2021, but it has [10]pre-announced the release of the analysis, coming
out in March or April 2023. The Coroners statistics for 2022 are also not
yet published. These are due to be published on [11]11 May 2023. A delay
between the year ending and the production of the annual report allows for
the analysis to be conducted and for quality assurance processes to be
completed. We have not and would not conduct our own analysis. As a
statistics regulator (rather than auditor), it is not appropriate for us
to conduct an analysis of data in advance of statistics being published.

2. Reporting deaths by the date of registration allows for the creation
of an incomplete record of mortality

As your email states, ONS have published various reports regarding the
benefit of using date of registration – primarily because it ensures that
data are complete for deaths registered in a given time period and allows
for comparisons over time. You are however correct in your assertion that
this results in an incomplete record of all deaths that occurred. This is
particularly apparent as deaths that are registered more than a year after
occurrence are not included in ONS’s weekly, monthly and annual mortality
publications. However, as these deaths tend to occur as a result of
external influences, they are usually covered in specific ONS
publications, such as those on [12]suicide, [13]drug-related deaths and
[14]alcohol-specific deaths.

3. ONS meeting the needs of users: You have asked how we can be
satisfied that ONS has met the needs of their users when you, as a user,
do not feel that your needs are met.

ONS previously reported the number of deaths occurring in a time period,
which meant that a period of time had to lapse before the analysis could
take place. This process was impacted by registration delays and as a
result, in 2006 ONS changed their methodology to their current method of
reporting on death registration. At the time of the change, this resulted
in a significant improvement, as it allowed for a much more timely release
of the data. ONS conducted a [15]user consultation in 2007 to determine
which methodology would best suit their users.

NHS Digital have published a [16]Mortality Data Review, which describes
the death registration process in detail. The flowchart on page five of
the document details the steps involved in the statutory reporting
process, and highlights areas where delays are likely to occur.

Yours sincerely

Ed Humpherson

Sent on behalf of Ed Humpherson, Director General for Regulation

From: Ferrier, Chris <[email address]>
Sent: 30 January 2023 12:48
To: [FOI #911352 email]
Subject: RE: Casework - Real time access to Mortality data

Dear Mr Smalley,

Thank you for your response to our email.

We acknowledge that there are limitations caused by primarily reporting
deaths data by the date of occurrence, as opposed to date of death (most
of ONS’s publications report the date the death is reported, but the
[17]Monthly Mortality Analysis also reports the date of death). This
method of reporting is subject to the effects of registration delays
(there are often delays in recording deaths over bank holidays, or deaths
recorded by coroners). We do however appreciate the merits of keeping a
static record of mortality, as opposed to a dynamic dataset that
constantly updates. Because of this, we intend to engage with ONS to
explore the ways in which some of these limitations could be mitigated.
This will be through the Compliance Check we outlined in our previous
email.

We would also like to acknowledge the steps taken by ONS to inform users
of the impacts of their focus on the date of registration rather than
occurrence, and the impact of registration delays on the data. In
addition, ONS conducts their own analysis of the [18]impacts of
registration delays on the data, and [19]provides data to allow users to
conduct their own analysis.

In response to our email, you outlined three questions. Our answers are as
follows:

With regards to registration delays, we have based our conclusions on the
latest published official statistics. These show that [20]registration
delays did increase in 2020. [21]Coroners statistics for 2021 indicate
that the number of deaths registered by a coroner dropped to the lowest
number since 1995. ONS has not yet published its analysis of registration
delays for 2021, but it has [22]pre-announced the release of the analysis,
coming out in March or April 2023. The Coroners statistics for 2022 are
also not yet published. These are due to be published on [23]11 May 2023.
A delay between the year ending and the production of the annual report
allows for the analysis to be conducted and for quality assurance
processes to be completed. We have not and would not conduct our own
analysis. As a statistics regulator (rather than auditor), it is not
appropriate for us to conduct an analysis of data in advance of statistics
being published.

2. Reporting deaths by the date of registration allows for the creation
of an incomplete record of mortality

As your email states, ONS have published various reports regarding the
benefit of using date of registration – primarily because it ensures that
data are complete for deaths registered in a given time period and allows
for comparisons over time. You are however correct in your assertion that
this results in an incomplete record of all deaths that occurred. This is
particularly apparent as deaths that are registered more than a year after
occurrence are not included in ONS’s weekly, monthly and annual mortality
publications. However, as these deaths tend to occur as a result of
external influences, they are usually covered in specific ONS
publications, such as those on [24]suicide, [25]drug-related deaths and
[26]alcohol-specific deaths.

3. ONS meeting the needs of users: You have asked how we can be satisfied
that ONS has met the needs of their users when you, as a user, do not
feel that your needs are met.

ONS previously reported the number of deaths occurring in a time period,
which meant that a period of time had to lapse before the analysis could
take place. This process was impacted by registration delays and as a
result, in 2006 ONS changed their methodology to their current method of
reporting on death registration. At the time of the change, this resulted
in a significant improvement, as it allowed for a much more timely release
of the data. ONS conducted a [27]user consultation in 2007 to determine
which methodology would best suit their users.

NHS Digital have published a [28]Mortality Data Review, which describes
the death registration process in detail. The flowchart on page five of
the document details the steps involved in the statutory reporting
process, and highlights areas where delays are likely to occur.

Yours sincerely

Ed Humpherson

Sent on behalf of Ed Humpherson, Director General for Regulation

Chris

Office for Statistics Regulation | UK Statistics Authority

[29]@StatsRegulation | [30]osr.statisticsauthority.gov.uk | [31]Privacy
Policy

For information on the work of the UK Statistics Authority, visit:
[32]http://www.statisticsauthority.gov.uk

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Legal Disclaimer: Any views expressed by the sender of this message are
not necessarily those of the UK Statistics Authority
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