HFMA response / HFMA response to proposals for possible changes to legislation

The consultation was wide ranging, so we asked several of our committees to contribute to our response.

The association is:

• Broadly in agreement with the proposals to promote collaboration by removing some of the competition requirements set out in current legislation
• In agreement with the proposals to amend s75 of the Health and Social Care Act 2012 but neutral on the proposals to replace the current Public Contract Regulations with a best value test
• In agreement with most of the proposed changes to the NHS payment system but neutral to those where we could not understand the rationale for the proposal
• Neutral on the proposals to establish new trusts to provide integrated care as we were not sure of the benefits it would provide
• Opposed to the proposals to give NHS Improvement powers to direct mergers of NHS foundation trusts or set annual capital spending limits for NHS foundation trusts
• In agreement with the proposals to enable the creation of joint committees but less supportive of the other proposals for working together mainly due to the potential for conflicts of interest
• Neutral on the proposal to create a shared duty to promote the ‘triple aim’ of better health for everyone, better care for all patients, and efficient use of NHS resources, both for their local system and for the wider NHS
• In agreement with the proposals to allow CCGs to work together
• In favour of the NHS England and NHS Improvement being combined
• Supportive of the proposals to allow collaboration between ALBs.

Our response identified two areas which were omitted from the consultation –the lack of proposals to address barriers to working with local government and the limited proposals in relation to primary care.