Please respond to this reorganisation of the NHS

Act to save our NHS

During the pandemic, the upper echelons of the NHS and the Government haver been implementing a structural reorganisation. The reorganisation breaks the national part of the NHS and integrates private companies into the reorganisation. It is being done without laws going through parliament.

The deadline for the response is 8th January, and the link to the consultation is https://www.engage.england.nhs.uk/survey/building-a-strong-integrated-care-system/

We have joined with other organisations to try to raise awareness of what is happening. Many people will be aghast that this is happening at all, but during the pandemic, when all eyes should be on the virus, is doubly scandalous.

We are reproduce here the letter from Keep Our NHS Public. Other organisations are circulating in essence the same message. What follows is from the material produced by Keep our NHS Public

Integrating Care: Why NHS England is getting it wrong

NHS England (NHSE) is consulting on their latest plans for ‘integrating care’, including changes to legislation.

The proposals include a top-down re-organisation of the NHS in England abolishing CCGs, replacing them with 42 Integrated Care Systems (ICSs), statutory bodies under tight financial control from the centre and with even less public accountability. The result will be massive new opportunities for the private sector through the ‘Health Systems Support Framework’ (HSSF). While ICSs will find it difficult to work in real partnership with others such as local authorities in addressing health inequalities, proposals will allow private companies representation on an ICS Board.

Despite the short notice we hope you can respond to the consultation, which has a deadline of 8th January.

We attach a template response to the consultation giving a range of possible answers for you to adapt.

We also attach background papers from Keep Our NHS Public:

     * Our summary of what lies behind the “Integrating Care” proposals

ICSs are an organisational form adapted from the US health insurance market, and the HSSF is central to their development. This Framework has 83 NHSE-accredited companies, 22 of which are US-based. We expect legislation will result in a flood of contracts, much as the government has dished out thousands of Covid contracts, bypassing proper procurement.

     * KONP’s response to the legislative proposals

These include a deregulated market economy in healthcare where even the existing, limited safeguards to protect social, environmental and labour standards are removed, and where a bidder’s track record is not taken into account.

Further detailed critiques of Integrating Care are available on the KONP website. These include a critique of the proposed structure and management of ICSs as revealed in NHSE’s Health Service Support Framework; critique of NHSE’s proposal to bring social care under NHS management; and proposals for real democratic accountability in the planning and oversight of NHS services as well as links to recent articles on ICSs in OurNHS/Open Democracy and The Lowdown (see https://keepournhspublic.com).

The Government has yet to publish a BillOnce it has, we look forward to your involvement in resisting this drive to disintegrate the NHS through financial mechanisms and increased corporate influence.

To reiterate, the deadline for the response is 8th January, and the link to the consultation is https://www.engage.england.nhs.uk/survey/building-a-strong-integrated-care-system/

Please do not worry about creating a long academic response. Please just respond. Try to keep a copy of your response and send it to  savelwh@outlook.com

Respond even if it is late.

Please write to your MP and please try to make sure your members know about this

Dear —

Integrating Care: Why NHS England is getting it wrong

NHS England (NHSE) is consulting on their latest plans for ‘integrating care’, including changes to legislation.

The proposals include a top-down re-organisation of the NHS in England abolishing CCGs, replacing them with 42 Integrated Care Systems (ICSs), statutory bodies under tight financial control from the centre and with even less public accountability. The result will be massive new opportunities for the private sector through the ‘Health Systems Support Framework’ (HSSF). While ICSs will find it difficult to work in real partnership with others such as local authorities in addressing health inequalities, proposals will allow private companies representation on an ICS Board.

Despite the short notice we hope you can respond to the consultation, which has a deadline of 8th January.

We attach a template response to the consultation giving a range of possible answers for you to adapt.

     * Our summary of what lies behind the “Integrating Care” proposals

ICSs are an organisational form adapted from the US health insurance market, and the HSSF is central to their development. This Framework has 83 NHSE-accredited companies, 22 of which are US-based. We expect legislation will result in a flood of contracts, much as the government has dished out thousands of Covid contracts, bypassing proper procurement.

     * KONP’s response to the legislative proposals

These include a deregulated market economy in healthcare where even the existing, limited safeguards to protect social, environmental and labour standards are removed, and where a bidder’s track record is not taken into account.

Further detailed critiques of Integrating Care are available on the KONP website. These include a critique of the proposed structure and management of ICSs as revealed in NHSE’s Health Service Support Framework; critique of NHSE’s proposal to bring social care under NHS management; and proposals for real democratic accountability in the planning and oversight of NHS services as well as links to recent articles on ICSs in OurNHS/Open Democracy and The Lowdown (see https://keepournhspublic.com).

The Government has yet to publish a Bill. Once it has, we look forward to your involvement in resisting this drive to disintegrate the NHS through financial mechanisms and increased corporate influence.

To reiterate, the deadline for the response is 8th January, and the link to the consultation is https://www.engage.england.nhs.uk/survey/building-a-strong-integrated-care-system/

In solidarity,

Keep Our NHS Public

NHSE CONSULTATION: building a strong, integrated care system across England

Please amend and adapt the wording below in your response to avoid any batch rejection of critical responses

 What is your name?  
 In what capacity are you responding?  
 Are you responding on behalf of an organisation?  
 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?
 Strongly disagree   comments or additional information: a)This is a very ‘top down’ exercise with little justification other than the hope it will allow tighter controls on spending. b) Claims that functioning ICSs have already demonstrated significant improvements in patient care are only wishful thinking and not evidence based. c) The plan for ICSs is not focussed on improving care for patients but on binding NHS organisations by financial controls and plans written by the ICS with advice from companies accredited under the Health Systems Support Framework. d) The NHS needs re-integration by abolishing the 2012 H&SC Act altogether and removing the competitive market and the purchaser-provider split. e) Facilitating even more contracting out of services and management structures including the private sector is not ‘integration’ but ‘dis-integration’. f) NHSE/I legislative proposals include the removal of Public Contracts Regulation safeguards over social, environmental and labour standards, and the ability to rule out bidders on the basis of their track record. It will expand the scope for scandals like the PPE contracts awarded without procurement to firms with no relevant experience. g) Other legislative proposals would embed “population health management” as a binding aim for all NHS organisations, without evidence that this will improve patient access to universal, comprehensive healthcare, free at the point of need, publicly provided and publicly accountable, funded through general taxation.  
 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?  
 Strongly disagree   comments or additional information: a) By “collaboration”, the plan includes collaboration with the private sector, which we oppose. b)  There is very little accountability built into the system and large organisations are inevitably far removed from the needs and concerns of local communities. CCG mergers reduce the opportunity for local public involvement; Option 2 goes even further. c) Any reorganisation of the NHS should be looking at increasing accountability and democratic control rather than weakening it.  
 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?  
 Strongly disagree   comments or additional information a) Allowing management consultants and private sector representatives to sit on governing bodies undermines the public sector ethos which is key to the NHS. b) ICSs as proposed will only facilitate top down control. c) The NHSE Health Systems Support Framework (HSSF) strongly prioritises financial savings over patient need. The HSSF is designed to implement systems of patient and data management needed for insurance-based systems rather than clinical priorities and local need. The majority of companies accredited through the HSSF are major corporates, including many involved in health insurance in the US and elsewhere. d) This approach is incompatible with what patients and communities want and need and with NHS founding principles and values.  
 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?  
 Strongly disagree   comments or additional information Specialist services require national commissioning in order to ensure consistent standards across the country  

Keep Our NHS Public (KONP) Overview Response to Integrating Care – The next steps to building strong and effective integrated care systems across England1

Introduction In the midst of a massive Covid epidemic, NHS England (NHSE) is driving through a far-reaching topdown reorganisation of the NHS, based on proposals in the Long Term Plan (2019). They are consulting until January 8 on the details of new legislation which they expect the government to enact early this year to give legal legitimacy to changes which are already under way. We are concerned that the implications of these changes for the accountability, availability and access to services and values underpinning the management of services have been barely noted within a tumultuous 2020. Noting the serious concerns that have been raised by the Local Government Association and others, including NHS Providers, we are asking all politicians, from every party, to take a stand against these damaging proposals.

Restructuring of the NHS in England .

At the core of the re-organisation are Integrated Care Systems (ICSs), bodies described by NHS England (NHSE) as NHS organisations that work in partnership with local councils and others to take collective responsibility for managing resources and delivering NHS care. ICSs have been driven from the top by NHS England, and in many areas resisted at local level by councils, GPs and campaigners.

However a 39-page NHSE document “Integrating Care,” seeking new legislation allowing the whole of England’s NHS to be run through ICSs by 2022, claims they are “a bottom-up response.” The proposals reduce the number of commissioning organisations from almost 200 to just 42 new “Integrated Care Systems” (ICSs). This has required merging (and eventually abolishing) local Clinical Commissioning Groups (established as public bodies by the Health & Social Care Act 2012), and replacing the 44 ‘Sustainability and Transformation Partnerships’ (STPs) set up in 2016.

The mergers inevitably result in larger bodies, more remote from the needs and concerns of any local community, and therefore a loss of local accountability. This point has been powerfully argued by the all-party Local Government Association (LGA), which represents the leaders of 335 of England’s 339 local authorities. Their response states: “We are concerned that the changes may result in a delegation of functions within a tight framework determined at the national level, where ICSs effectively bypass or replace existing accountable, place-based partnerships for health and wellbeing…. 1

https://www.england.nhs.uk/integratedcare/integrated-care-systems/ 2

Calling this body an integrated care system is to us a misnomer because it is primarily an NHS body, integrating the local NHS, not the whole health, wellbeing and social care system.”

The Health Service Journal, aimed at NHS managers, has also shown how vague the proposals are: “ICSs will be given a single pot of money from which to manage spending priorities. But there is no framework for how this will be spent that assures fairness, value for money and quality outcomes.”

29 of the proposed 42 ICSs have already been approved by NHS England – even though they lack any legal status, and almost all are functioning behind closed doors with no public accountability. The remaining 13 STPs2 are required to become ICSs by April, or face the intervention of an “intensive recovery support programme.”

The LGA calls for the establishment of alternative structures involving genuine partnership with local authorities and, through them, links to local authority services and responsibilities that are vital components of the wider determinants of health.

Keep Our NHS Public (KONP) has issued a response to the lack of public accountability inherent in ICS structures, and set out proposals for developing genuine public accountability. The Report is on the KONP website here. KONP also rejects the assumption, repeated frequently throughout ‘Integrating Care’, that social care might be managed through NHS ICS structures. KONP campaigns for a publicly provided national care, support and independent living service.

At local level, we argue it is essential that social care continues to be managed by local authorities, retaining essential links to wider local authority responsibilities such as housing, education and leisure. KONP’s critique of the approach to social care set out in Integrating Care is here.

New legislative proposals Integrating Care seeks new legislation that would provide the formal legal basis for ICSs that they currently lack, as well as changes to existing procurement requirements. KONP argues for the abolition of the commissioner-provider split, believing the NHS should be provided and managed directly as a public service, not through commercial contracts. However we argue that what is worse than a managed market in health is an unmanaged and unregulated market.

The failed £multi-billion Covid-related contracts, including those for PPE or Test and Trace, dished out with no proper procurement procedures, have revealed what this can mean in reality.

NHSE wants to scrap Section 75 of the 2012 Health & Social Care Act which requires significant contracts to be put out to competitive tender, and to remove contracts from Public Contracts Regulations.

The prospect of changing the law so that more and more large NHS contracts could be awarded without any due process or public scrutiny is seriously worrying. KONP’s detailed response to the legislative proposals in Integrating Care is here.

Values underpinning the management and direction of ICSs Under proposals for ICSs, all providers will be bound by a plan written by the ICS Board and financial controls linked to that plan. Private companies may support the Board and potentially have a place on the Board, as well as being contracted for services.

NHS England has established a Health Systems Support Framework (HSSF) to facilitate easy contracting by ICSs. The Framework consists of organisations accredited by NHS England to support the development of internal structure and management of ICSs, and, potentially, also to play a longterm role in direct management of ICSs. A quarter of the 83 organisations approved by NHSE to take on contracts with ICSs, and potentially also take seats on decision-making Boards of ICSs (as has happened in North East London) are American-based, offering expensive data-based systems designed to benefit US insurance companies and private hospital chains.

Research in the USA and experience in England has exposed the lack of evidence that data-led attempts at “population health management,” or targeting the small number of patients with complex medical and social needs, can either reduce demand or cut costs. However, such approaches do facilitate the development of private insurance pathways running alongside NHS care.

Digital technology and number-crunching are among the more lucrative areas in which private companies are seeking profitable NHS contracts, and this is a strong theme running through the HSSF. However digital and data are also areas of notorious recent private sector failures – including the Covid-tracking app, the privately-run test and trace system, Capita’s long delays in contacting professional staff offering to return to fight the pandemic, and the £10 billion saga of the NHS Programme for IT.

And while Integrating Care argues for the need to establish ICSs as “statutory bodies” with real powers, notably “the capacity to … direct resources to improve service provision,” there are real fears that NHS England sees ICSs and ‘system-wide’ policing of finances as a way of more ruthlessly enforcing cash limits and “control totals” limiting spending across each ICS, with growing lists of excluded “procedures of limited clinical value”. These approaches to structure and management of ICSs pose a major threat to the NHS, distorting and undermining the core values and ethos of the NHS.

Conclusion Integrating Care raises serious concerns for the future of the NHS and social care services, concerns that we set out in detail in papers available on the KONP website, along with proposals for alternative structures and why social care should remain the responsibility of local authorities. Our concerns, based on hard facts, are widely shared by councillors, senior NHS management, GPs and seasoned analysts. NHS England’s proposed changes threaten to make the NHS less locally responsive, less accountable, more dominated by US and other management consultants and contractors, and more focused on policing cash limits than meeting the needs of patients. NHS England’s priorities should be on strengthening the NHS in alliance with local government and communities, not creating new remote bodies or adopting systems meant to maximise profits of private health insurance. Keep Our NHS Public (KONP) January 2021 https://keepournhspublic.com/

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