Dear (MP/ Councillor)
INTEGRATED CARE SYSTEMS (ICSs):
The development of the ICS is part of national rollout of 42 ICSs across England. Some authorities and NHS bodies have seized the opportunity to work collaboratively, but in many ICSs, local authorities will be sidelined. In addition, Government proposals allow major corporates to take a central role in the development and ongoing management of ICSs.
We would like to draw your attention to the attached summary briefing outlining our concerns about Integrated Care Systems (ICSs) and legislative proposals outlined in NHSE’s consultation document that would put ICSs on a legal footing.
We believe that ICSs will hugely increase the presence and influence of private companies within the NHS, whether as members of an ICS Board, or as companies included in the Health Systems Support Framework (HSSF) that are accredited to support the development and management of ICSs. But on top of this, ICSs raise particular concerns for local authorities.
NHS England and NHS Improvement (NHSE/I) describe ICSs as NHS organisations that, in partnership with local councils and others, take collective responsibility for managing resources, delivering NHS standards and improving the health of the populations they serve.
The Local Government Association (LGA) has raised concerns that the partnerships that NHSE/I refers to may not be partnerships of equals. Along with other bodies, it has called for decision-making to be as close to communities as possible. However, the LGA remains uncertain whether the proposals really mean that NHSE/I intends to move from “a centralised command and control organisation to one in which power and resources will be devolved to systems and places”. The current indications are that NHSE/I assumes it will keep central control, with, for example, NHS regional teams responsible for oversight of ICS performance.
Each ICS will have a single plan that is binding: proposals include that all organisations within an ICS will have a duty to collaborate, with no right of veto. At the same time, there will be a ‘single pot’ budget, with all ICS ‘partners’ held collectively accountable for delivering the ICS system control total, with financial risk managed between collaborating partners. This raises concerns that LA resources, such as capital assets and funding for social care and public health, will be brought under ICS (and thus NHS) control.
Finally, in contrast to local authorities, ICSs are not subject to democratic control. The legislation that NHSE wants will give ICSs the power to create publicly unaccountable joint committees that would make legally binding decisions about major resource allocation and service provision. Although ICS Boards will replace existing public bodies, there appears to be no requirement for them to meet in public, publish their Board papers and minutes, be subject to the Freedom of Information Act, or to have any democratic participation from the communities they cover.
We understand that a strong partnership between the NHS and Local Authorities is central to improving the health and wellbeing of local communities, but we fear that NHSE/I’s preferred legislative option will create unaccountable NHS-led organisations in which the values that underpin local government are undermined.
We therefore urge you to:
1. To demand an immediate halt to the rollout of ICSs.
2. To demand extended and meaningful consultation with the public and Parliament to decide how health and social care services are provided in England.
3. To promote the introduction of legislation to bring about a universal, comprehensive and publicly provided NHS, fit for the 21st century (as set out in the NHS Bill at www.nhsbillnow.org)
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