Integrated Care Systems

Government NHS White Paper sets out proposals to implement Integrated Care Systems (ICSs)

The Government’s White Paper ‘Integration and Innovation: working together to improve health and social care for all’ sets out its proposals for the future structure and operation of the NHS.  The proposals will provide a legal basis for the 42 ICSs across England that have been in development since 2014, and will hasten privatisation in both clinical services and management of the NHS through a new permissive procurement regime.

In the midst of a massive COVID-19 epidemic, the government is driving through a far-reaching top-down reorganisation, using a strategy set out by NHS England (NHSE) based on proposals in the Long Term Plan (2019). 

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.

The White Paper acknowledges that "there is no legal basis at present for Clinical Commissioning Groups (CCGs), NHS trusts and Foundation Trusts (FTs) to form a joint committee to which functions may be delegated, with the power to make decisions on behalf of the organisations within the ICS." From the White Paper, these organisations will include NHS trusts, general practice, local authorities, and others determined locally.

Nonetheless, some areas, like North East London, are already declaring themselves to be an ICS from 1 April 2021, before a Bill is even tabled, let alone approved by Parliament. In other areas, like Cheshire & Merseyside, CCGs have or will form Joint Committees to take decisions on a restricted set of topics over the coming year.  Greater Manchester (which as ‘Devo Manc’ became a ‘devolved’ authority in 2015) says it has been recognised as an integrated care system since 2018, but in a paper to the Health and Care Board on 26 March 2021, also said that it would only be “from April 2022 the GM ICS will receive almost all of the NHS funds allocated to GM and be accountable for using these resources to meet national NHS requirements and our GM health and care ambitions.” So GM is not fully an ICS yet.

NHSE’s proposal was: “From April 2021 this will require all parts of our health and care system to work together as Integrated Care Systems”, even though there is not yet any legal backing for them, and many issues are still to be worked out, including the way that finances would be distributed, operational delivery arrangements, workforce planning, the use of digital and data to drive system working and improved outcomes.  The Government White Paper, produced in February 2021 just after the NHSE consultation on ICS had finished, confirms support for the NHSE proposals.  Far from being just another reorganisation of NHS bureaucracy, this is potentially one of the final steps in the fragmentation and privatisation of the NHS.

KONP is calling for a halt to the development of ICSs until there is a full consultation with the public, local authorities and Parliament. We call on activists to make these issues a campaign focus, before new legislation on ICSs is tabled on the back of the White Paper.

Sign our petition to Stop ICS Roll Out in England

Please sign the petition and pass it on to others to sign, to Stop the Roll Out of ICS.


Why we need to campaign

This page of the KONP website gives a brief outline of why we are deeply concerned about ICSs. It also provides a range of resources such as briefings and campaign materials for use by local groups. 

At the moment, ICSs are not statutory bodies but recent proposals set out in an NHS England (NHSE) consultation and the government’s White Paper on health and social care ‘Integration and innovation: working together to improve health and social care for all’, February 2021, aim to give them a formal legal basis.  These proposals and related NHSE documents also show the government’s intentions to:

  • embed the private sector throughout the NHS, for example, increasing dependence on firms accredited by NHSE to develop ICS (the Health Systems Support Framework), including many global corporations.
  • remove Section 75 of the Health and Social Care Act and associated regulations and remove the NHS from the Public Contracts Regulations. This will, in effect maintain the purchaser/provider split while replacing a regulated market with an unregulated one, without environmental, social and labour protections.
  • enable the Boards of ICSs to include private companies, allowing them to influence which services are delivered and by whom.
  • make ‘population health management’ the basis for deciding priorities and planning health services, shifting the focus of the NHS away from providing universal comprehensive health care. Using data to set targets for the health of the population of an ICS area prioritises demand-management over clinical need and may give firms access to the data.
  • tighten central control of the NHS, for example by removing Local Authority powers to refer reconfiguration proposals to the Secretary of State for Health and Social Care. The geographical size of ICSs, with mergers and ultimately abolition of CCGs, will concentrate decision-making at a level much more distant from local populations
  • ensure the compliance of NHS organisations within an ICS (see White Paper 5.17-5.18) through a legal duty to collaborate on “sustainable use of NHS resources” and the “best interest of … the ICS as a whole”, binding NHS providers to a plan written by the ICS Board and to financial controls linked to that plan.
  • impose a duty on local authorities to collaborate with ICSs and NHS providers, subject to guidance from the Secretary of State for Health and Social Care. The Government “expect local authorities and NHS bodies to work together under one system umbrella”. (see White Paper, 5.15-5.16). 
  • ignore the ‘democratic deficit’: neither the ICS proposals nor the White Paper mention making ICSs or the NHS as a whole democratically accountable. Elected local authorities could lose some control of a major part of their work, social care.   In response to Local Government Association objections, the White Paper suggests a two tier system for ICSs, an NHS body responsible for day to day running of the ICS and the plan, commissioning and budgets, with representation from local authorities and unspecified others, and a Health and Care Partnership to support integration, including public health and social care, and representation including independent sector partners and social care providers.  However, the relationship between decision-making at the ICS NHS Body and the Partnership is not explicit, and “will allow systems to decide how much or how little to do at these different levels and will also potentially allow them to vary these arrangements over time as the system matures and adapts.”  So local authorities would not be equal partners.

Keep Our NHS Public demands:

  • a halt to the development of ICSs until there is a full consultation with the public, local authorities and Parliament.
  • the entire Health and Social Care Act (2012) to be repealed and the NHS Reinstatement Bill laid before Parliament. This proposes restoring the NHS as an accountable public service; ending contracting and the purchaser-provider split; and re-establishing public bodies and public accountability to local communities.

Resources from the KONP ICS Working Group

Briefing Documents on ICSs and the White Paper ‘Integration and Innovation: working together to improve health and social care for all’

The following documents have been produced by Keep Our NHS Public in order to help campaigners fighting to oppose the roll out of ICSs in England's NHS and their implementation by legislation proposed in the White Paper. 


The earlier documents (November and December 2020 and January 2021) were to help campaigners respond to the NHSE consultation on ICSs, and provide analysis of the NHSE proposals. They remain relevant as the White Paper implemented the NHSE strategy. 

·      Integrated Care Systems: How Keep Our NHS Public should be campaigning on Integrated Care Systems, November 2020

KONP provided information to help people respond to the NHSE consultation which closed on 8th January 2021 (the NHSE consultation: Respond to the consultation)

The White Paper

KONP had responded to legislative proposals in 2019; this paper has been updated to take account of the latest proposals.  It confirms that partial reform can be dangerous: repealing just part of the Health and Social Care Act 2012 would not end privatisation of the NHS but would embed it further.

More information about the Government’s White Paper and the proposals it makes to give legal status to ICSs can be found in the following articles:

The NHS White Paper: Government seizes on the pandemic as an opportunity. NHS White Paper: Government seizes on the pandemic as an opportunity.

Detailed analysis and comments on the White Paper:

A detailed overview on ISCs and the White Paper legislative proposals 

Comment on the leaked government proposals just before the White Paper was published: White Paper: power grab, sea change or cementing in the status quo? The Lowdown 9th February 2021

Campaign Materials

The following documents have been produced by Keep Our NHS Public in order to help campaigners to lobby Councillors and MPs and call on them to oppose the roll out of ICSs in England's NHS, and for use in public campaigning. 

Noting the serious concerns that have been raised by the Local Government Association and others, including NHS Providers, Keep Our NHS Public is asking all politicians, from every party, to take a stand against these damaging proposals.

The Model Motions can be adapted to take account of local information:

And remember to ask everyone to sign the Petition to Stop the ICS Roll Out

Other resources