CCA consultation response: NHSEI – Building a strong, integrated care system across England

CCA consultation response

NHSEI: Building a strong, integrated care system across England

Consultation launch:                  26 November 2020

Deadline for responding:           8 January 2021


NHS England and NHS Improvement asked patients, NHS staff, partner organisations and interested members of the public to give their views on proposals set out in the document Integrated Care: next steps to build strong and effective integrated care systems across England, which details their vision for a more effective and responsive care system across England. This document sets out how NHS organisations, local councils, frontline professionals and others will join forces in an integrated care system (ICS) in every part of England from April 2021.

Consultation questions: CCA response

The consultation was in the form of an online survey with four questions. Respondents were asked to respond with one of the following options: Strongly Agree, Agree, Neutral, Disagree, or to Strongly Disagree.  There was also a text box to submit additional information. (N.B questions 1-3 were purely for identifying the respondent’s details).

  1. Do you agree that giving ICSs a statutory footing from 2022, alongside other legislative proposals, provides the right foundation for the NHS over the next decade?
  • Neutral

We believe that the current statutory structure of the NHS, introduced in 2012 with its aim to artificially introduce competition and patient choice to drive improvement, has not worked. We can see the merits in moving towards a locally based system, with fewer constituent parts, providing all the care needs for a population. However, we are concerned that without wholesale restructuring there is a danger that whilst the proposals create the legal ability for changes to be made, the incentives are not strong enough to change system structures, cultures or behaviours, in order to actually deliver better outcomes or value. There is a risk that existing siloed positions will continue to frustrate the ambitions for change at a system level if only local job titles are changed. The introduction of new statutory bodies, without a comprehensive structural change, may mean that a legally binding sticking plaster is being applied to what is still at times a dysfunctional system. In addition, we would expect for there to be absolute clarity for the remits and responsibilities of all remaining bodies and structures to avoid any conflicts, gaps in care or duplication of effort.

  1. Do you agree that option 2 offers a model that provides greater incentive for collaboration alongside clarity of accountability across systems, to Parliament and most importantly, to patients?
  • Agree

We believe that the introduction of an Accountable Officer role as ‘Primus inter pares’ will NOT provide a structure with sufficient clarity of accountability to successfully deliver the purposes of these proposals. We therefore agree that option 2 is the better of the two options put forward in this consultation.

  1. Do you agree that, other than mandatory participation of NHS bodies and Local Authorities, membership should be sufficiently permissive to allow systems to shape their own governance arrangements to best suit their populations needs?
  • Agree

System membership should be representative of all bodies/organisations who actively contribute towards the health and care of the population within the ICS, including community pharmacies. There must be mandatory inclusion of local representational bodies such as LMCs, LDCs, LOCs and LPCs within the ICS governance structures. We are very clear that no one group, or profession, should hold a majority position for decisions made in any system. Systems should have sufficient transparency, rigour and governance to ensure that care is commissioned and provided in such a way so that patients receive the best possible outcomes, and the taxpayer gets the best possible value for their investment.

  1. Do you agree, subject to appropriate safeguards and where appropriate, that services currently commissioned by NHSE should be either transferred or delegated to ICS bodies?
  • Disagree

We recognise that in the spirit of moving decision making closer to those who receive the care, moving centralised commissioning to a more local level, can be advantageous. However, we cannot support the transference of commissioning locale for all nationally commissioned services.

Currently there are several services, and other elements of care provision, that are commissioned centrally by NHS England for which local commissioning would prove highly inefficient and could result in significant inequalities in outcomes for local populations. Community pharmacies are commissioned by NHSE, via the Community Pharmacy Contractual Framework, to provide essential and advanced services such as the supply of medicines. People need medicines regardless of where they are (similarly they need flu jabs). Such national level contractual agreements mean that patients can receive the same high-quality care wherever they are in England. To introduce a system where regional variances could emerge would impact significantly in the quality and equity of care provision.  Other advantages of nationally agreed contractual frameworks include the ability to maximise the synergies and reduce any unintended duplication.

We do see, however, value in supplementary care over and above a core that meets a specific local need, which can objectively be classed as different to national. This currently sits primarily with CCGs and there is value in ICSs being able to use their scale and system level oversight to commission more effectively. We see a clear role for NHS England and the NHS Regions in ensuring that there is no unnecessary duplication of effort by ICSs, coordinating delivery of specialist services, supporting mutual aid, and overseeing research and innovation projects. This would also provide clear national accountability through the Regions to the NHS England Board and to Parliament.

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