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logo Integrated Care Systems Consultation: Very little time to respond

March 25, 2021 3:45 PM / by Nils Christiansen Nils Christiansen
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NHS England recently issued a consultation on significantly extending the role of Integrated Care Systems (ICSs) in the NHS. The proposals are very far reaching for Primary Care as well as other NHS providers, and the consultation is set to close on 8 January 2021 so time is short.

What are the Proposals?

ICSs have been around for a couple of years now, and bring together CCGs, Trusts, Councils and other NHS Organisations to ‘take collective responsibility for managing resources, delivering NHS standards, and improving the health of the population they serve”. To date ICSs have been collaborations between existing organisations rather than creating anything new.

At heart, the proposals in the consultation paper are to put the ICSs on a firmer footing by introducing new legislation. There are 2 options presented, and it should be noted that ‘Doing Nothing’ is not an option. The implicit conclusion must be that the current organisation of the NHS in England is no longer considered fit for purpose. The options are:

Option 1: a statutory committee model with an Accountable Officer that ‘binds together’ current statutory organisations

Option 2: a statutory corporate NHS body model that additionally brings CCG statutory functions into the ICS.

There is a clear preference in the paper for Option 2. Under this model the current GP-led CCG model would disappear and CCG functions would move into ICSs. ICSs would instead be governed by a board consisting of representatives from the ‘system partners’, including, as a minimum, representatives of NHS providers, primary care and local government.

Under Option 2, ‘many commissioning functions for which NHSE is currently responsible could be transferred or delegated to the ICS’. Critically, it also anticipates allocating ‘combined population-level primary care, community health services and specialised services population budgets to ICSs under this option. There is no doubt that these proposals are very far reaching and, if adopted by the government, will see a radical change to the NHS in England. They will also open the door to a very different role for primary care and we will analyse these changes in a separate blog.

How to respond?

The Consultation poses 4 questions, and asks for responses by 8 January 2021. The questions are all framed as ‘Do you agree that…’ so you will need to be clear in your answers if you actually disagree with any of the statements. The four questions are:

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?

2. 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?

3. 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?

4. 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?

Quite how NHSE expects to receive carefully considered responses to such far-reaching proposals in a tight timescale in the midst of a Covid pandemic, during the flu season, and over the Christmas period is not explained. Although we would obviously recommend that readers respond by 8 January if they can, we would suggest that if you would like to respond but feel that the deadlines are too tight, as a minimum you notify NHSE of this so that later representations may possibly be considered.

If you wish to discuss the impacts of any of these changes on your practice, PCN or federation, please contact Nils Christiansen on 01483 511555, [email protected]