Our key points are:
- The two-tier approach to ICS governance is likely to add complexity and bureaucracy to the system.
- There continues to be a conflict between system and organisational statutory duties.
- The Health and Care Bill is already impacting relationships between the NHS and local authority in some local systems, as a consequence of the bill’s focus on the NHS for decision making and oversight through the integrated care board (ICB).
- It is disappointing that there is no explicit requirement in the bill to include a chief financial officer on the ICB board, as this role is fundamental to the efficient running of the ICS.
- It is essential that financial allocations to ICBs are fair and transparent, with flexibility to meet local priorities.
- The short-term nature of NHS funding allocations must be addressed in the comprehensive spending review as the success of ICSs will be impeded by an inability to plan for the long term.
- Integration is important to improving care, but it must be supported by sufficient funding to recognise the ongoing impact of the Covid-19 pandemic across the health and care system.
- The continued underfunding of social care means that true system working cannot be achieved for the benefit of those who rely on the health and care system.
- Although it is impossible to legislate for relationships, it is essential to provide a statutory framework that local systems can fall back on, should relationships fail.
- The duty to collaborate set out in the bill Integration and innovation: working together to improve health and social care for all should be reinstated in the bill.
- Data sharing is vital for effective system working and the data sharing strategy should be accelerated to provide benefit for patients in advance of any structural changes.
- The need for longer term capital allocations continues to be an issue for the NHS and the additional reserve power does not address this underlying problem.
- Changes to procurement and competition rules are welcome but the larger ICS footprint means that it is essential to maintain local relationships to support place-based services.
- Procurement and competition rule changes must be applied equally to all ICS partners to allow joint commissioning of services, and existing regulatory structures such as section 75 of the NHS Act 2006 must be reviewed to enable this.
- While we support the direction of travel, the demands placed on finance staff to enact the changes through the closedown and set up of organisations, are significant. The time to do this properly must not be underestimated. We are concerned at the potential risks that may be created if insufficient time is allowed to complete the process.
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