How Keep Our NHS Public should be campaigning on Integrated Care Systems

The clear and present danger for the NHS – how do we respond?

It has never been clearer than during this pandemic just how important the NHS is to the safety of the public and the health and care of individual people. Yet the NHS was left to face the pandemic already severely damaged by government policy: all the areas of deliberate neglect – underfunding, fragmentation, repeated restructuring and privatisation – are the very areas where the NHS and the public have been most exposed to risk.

Prior damage done to national health services

The political failings are many and dangerous: the failure to respond to pandemic modelling; the failure to procure and provide fit-for-purpose PPE for health and care staff and other frontline workers; the reduction in acute beds to below 100,000 – overall the NHS has less than one third the beds available in Germany; the deliberate cutting back on training of doctors and nurses from 2010 and failed workforce planning leaving the NHS with 100,000 hospital staff vacancies including 40,000 nurses and 10,000 doctors, and a shortage of over 7000 GPs; Germany has 50% more doctors, 60% more nurses, three times the number of MRI and CT scanners; the failure to provide funding to maintain hospital and community buildings to a safe and sufficient capacity, with over £6b shortfall in capital expenditure.

By-passing local public health, cronyism and failed political response

The Government’s disgraceful response to Covid has been to bypass local public health and local authorities, GP practices, NHS and university laboratories and instead to waste over £12bn in inadequate test and trace and over £15bn in private procurement contracts, with differential awards going to political cronies, friends and contacts.  Most of which has been a public scandal and an embarrassing failure.

Escalating centralisation and private outsourcing and legal plans to lock in these policies

In the face of failed centralised outsourcing, far from resolving to repair the NHS and build it up to a capacity to meet the needs of the population from Covid and non-Covid work, the Government and NHS England are planning ongoing sweeping changes to restructure and centralise NHS bodies and decision-making, including an escalation of outsourcing by contract of clinical services, clinical support services and digital-led population health segmentation and demand management.

Merged CCGs and integrated care systems

NHS England has pushed through a policy to merge what were 210 clinical commissioning groups (CCGs) created by the Health & Social Care Act 2012 (HSCA) into 42 merged CCGs co-terminous with the 42 geographically-based integrated care systems (ICSs) that NHSE is imposing to an April 2021 deadline. Not all areas have agreed CCG mergers and only 18 ICSs are in existence to date. Those areas where CCGs have not yet merged, or refused to do so, are being coerced into doing so by April. Then each area must also have its ICS in place. Other centralising plans are underway for example the imposition of 42 pathology networks.

Unprecedented challenge

The scale of deaths is tragic – over 70,000 excess deaths (52,000 directly Covid-related), 20,000 in care homes, 3600 excess deaths in home settings and over 600 NHS and care staff. Covid has exposed the need for urgent restoration of a public health system and fully funded and larger publicly provided NHS. We need urgently restored, upgraded hospitals, more beds and staff, far better funded primary (GP) care and community services, including dramatically improved mental health and disability services. Covid has also shown the potential value of some emergency measures including the rapid development of more telephone consultation and IT-led information exchange. However, Covid has also revealed the heightened dangers of social and economic inequality, disproportionately disadvantaging people of BAME origin, disabled people, those relying on social care and support in their own homes and communities or in care homes.

Campaigning challenge

In this high-risk, politically tense context, how do campaigners best respond to get our message to the general population? How do we aid the transition from passive clapping and thanks for the NHS and social care staff to active demands for a changed attitude to our public services in health and care? How do we most effectively put a stop to undemocratic centralisation, rationing of NHS care, and entrenchment of private companies in the running of the NHS managerially, administratively digitally and yes, in clinical services too?

We have to engage with the public, explain the pressures on the NHS, highlight and explain the dangers it has faced and make the connection between the everyday experiences of people in health and social care and the political failures of this government.

A hijack of language: ‘integrated’

NHS England has hijacked the word “integrated” and by use of it in the jargon term “Integrated Care Systems” has effectively inverted its meaning.

By contrast ever since the NHS was carved up into purchasers and providers by Margaret Thatcher’s “internal market” reorganisation in 1989-90, and since the slicing off from the NHS and almost complete privatisation of long-term care for mental health and elderly patients in the so-called “Community Care reforms” from 1993, campaigners have been demanding the services need to be reintegrated, with the scrapping of the market.

In place of the reintegration of England’s health services into a single, publicly-owned, controlled and provided NHS, or combining health with some aspects of social care through local boards as has taken place in Scotland and Wales, NHS England has taken a very different path.

“Integrated Care Systems” (ICSs)– the latest incarnation of a notion that originated in the “Accountable Care Organisations” (ACOs) referred to vaguely in the 2014 Five Year Forward View, the subsequent 44 STPs “Sustainability and Transformation Plans” (STPs) (and later “Partnerships”) that NHS England ordered to be developed in secret during 2016, and the call in last year’s Long Term Plan for 42 ICSs  – are the ultimate misnomer:

  • they involve a further DIS-integration of the NHS into more contracts, including many with private providers;
  • they are not focused on patient care but on financial balance sheets,
  • and they are only ‘systems’ insofar as they allow far greater top-down control by NHS England over the decisions and activity of each locality.

KONP has consistently opposed the establishment of ACOs, ACSs, STPs, ICSs and ICPs[1] on the basis that they undermine and obstruct any local accountability, prioritise financial controls over patient care, and open the door to new forms and levels of privatisation.

But the extent to which we have been able to build significant campaigns on such issues and explain what’s at stake to a wider population has been limited, and the extent to which we should prioritise it now is a subject of some debate.

The challenge

The challenge for campaigners fighting the introduction of Integrated Care Systems is to find ways to draw public attention to what have been secretive and uneven changes, explain their significance, and identify those issues which a wider local public might see as reasons to take political action – and actions which they might see as likely to make a difference.

This challenge is tough enough on its own.

A campaign now on ICSs would have to be conveyed in an accessible way, and gain publicity  in the midst of a pandemic – and the veritable tsunami it has unleashed of high-profile large-scale diversion of tens of billions of public funds to private contractors (£12 billion on Deloitte/Serco test and trace) dodgy private providers (£15 billion of PPE contracts) and private hospitals (upwards of £3 billion this year with up to £10 billion over the next 4 years).

Any campaign on these issues by KONP therefore needs to recognise:

  • the limited public audience for discussion of what appear to many to be complex and obscure questions at a time when NHS staff and public alike have been focused on the immediate issues raised by Covid-19, staff shortages, waiting times, under-funding and privatisation;
  • the limited public awareness of, affection for, and willingness to defend CCGs, which were only established from 2013 as a result of unpopular legislation which is still poorly understood. Many CCGs have also acted in high-handed and undemocratic fashion, making them unlikely bastions of local accountability;
  • the weakened position of local government in many areas, limiting the extent to which they feel confident to take any leading role in challenging ICSs or the erosion of local scrutiny and accountability after more than a decade of brutal spending cuts. This is made worse by the need to secure additional government funding to address local Covid response, the priority of challenging for control over local test and trace, and the relatively limited number of councillors who have ever taken any detailed interest in the NHS;
  • the problem posed by the widespread lack of any overt activity by most of the 18 ICSs that have been established and mainly function under the radar of local news, making it even more difficult to galvanise local interest or to demonstrate what dangers they might pose in future;
  • the pressures on campaigners to respond to the latest twists and turns of government policy, which leaves many with insufficient time and energy to follow the complex, obscure and largely dull literature on ICSs.

None of these is a reason why we should not attempt to campaign on the threat posed by ICSs, but we need to be clear on how far we wish to prioritise this work given limited energy, resources and scope to organise openly during and beyond further lockdowns and continued restricted social interaction.

Under cover of Covid

There have been alarming developments this year, as far-reaching changes have been pushed through in meetings held secretively during the lockdown, and via letters of instruction which appear to be responding to the pandemic.

Prior to and during the Covid pandemic, NHS England has stepped up the pressure for the wholesale merger of CCGs, reducing to a barely detectable minimum any remaining local accountability.

At the end of April NHS the Lowdown reported England’s London director Sir David Sloman had sent out a letter that has not been made public, requiring Integrated Care System Chairs and Senior Responsible Officers to take “urgent action” on system plans for London that “fundamentally change the way we deliver health and care.”

Each ICS was ordered to supply a “revised ICS plan” by Monday May 11 2020. The letter spelled out a 12-point list of issues on which bureaucrats in each area were told to devise new policy, on the hoof, for a “Recovery Board” meeting on May 13. Even if the country had not been on lockdown, this 12-day turn-round period for proposals on fundamental changes for “a New Health and Care system for London”, to be in place by November 2021, would indicate a complete disregard for any serious consultation or discussion.

But it’s clear from the way this was done that any notion of public engagement or accountability is a very low priority afterthought.  The accompanying Powerpoint presentation entitled ‘Journey to a New Health and Care System’ stated the hope that over the next 12-15 months they would be able to keep public engagement to a bare minimum: “Include public and stakeholders in the process within the constraints of an emergency”.

The pressure to consolidate the ICSs – long before the legislation required to give them any legitimacy – was clearly summed up in the edicts included in a July 31 letter to local NHS trusts and commissioners, which appeared to be about services after the peak of the pandemic, but made it clear that NHS England was unwilling to let a good crisis go to waste.

Under “Financial arrangements and system working,” in addition to CCG mergers it pressed for more rapid implementation of the drive towards the imposition of “integrated care systems” and new measures to eliminate even the pretence of public consultation. All “ICSs and STPs” were required to draw up a ‘development plan’, which had to include: “Collaborative leadership arrangements, agreed by all partners, that support joint working and quick, effective decision-making. This should include a single STP/ICS leader and a non-executive chair, appointed in line with NHSE/I guidance…” (p9).

Three further plans also had to be drawn up at a rapid pace, with tight timescales across the peak holiday period making it impossible for there to be any local consultation or genuine involvement in producing them. These included: (a) “Plans to streamline commissioning through a single ICS/STP approach. This will typically lead to a single CCG across the system”; (b) “A plan for developing and implementing a full shared care record, allowing the safe flow of patient data between care settings, and the aggregation of data for population health”; and (c) “a draft summary plan by 1 September … with final plans due by 21 September.”

Pushing through the CCG mergers has involved piling pressure onto local opponents (mainly GPs) who in a few areas have stood out against these mergers, and further marginalising any local authorities which have challenged the loss of their residual scrutiny powers.

Some local authorities, to their credit, have gone beyond opposing CCG mergers and also resisted the incorporation of local government into Integrated Care Systems.

Basis for opposition to ICSs

Centralisation and loss of local democracy

ICSs are set up from top down as a bureaucratic fait accompli, with no public consultation or support. They involve not only CCG mergers, but also even larger-scale mergers of hospital and of mental health trusts – each merger cutting any genuine local links and accountability that might have survived the past 30 years of reorganisations and market-style policies.

Loss of accountability

ICSs lack any legal standing or accountability, and are part of a wider NHS England project to enforce tighter regional-level control over cash-limited budgets, impose restrictions on the range of services provided by the NHS, and drive through new data-led schemes for ‘population health management’ along with a “digital first” agenda that create huge new lucrative openings for private sector bodies while threatening to leave millions of people increasingly excluded. (These latter dangers have been underlined by the recent report from Healthwatch Derbyshire on the use of virtual appointments during the lockdown.)

‘Contract killing’ the NHS

NHS England has also set up the Health Systems Support Framework (HSSF), to facilitate even more rapid and easy involvement of private sector management consultants, number crunchers and other providers in the new ICSs. The HSSF is a list of accredited companies (plus a few NHS providers) offering trusts and CCGs a range of services that can “support the move to integrated models of care based on intelligence-led population health management”.

The HSSF has established a series of “framework contracts,” through which companies seeking contracts can secure pre-approval, allowing contracts to be awarded without a tendering process, either with no competition or through a ‘mini-competition’ between companies on the list.

This is a complex area: but nevertheless worthy of the vigilance and scrutiny of local campaigners.

NHS England, the 2012 Act and impending new legislation

NHS England has argued for more than two years for legislation to make partial reforms to the 2012 Health and Social Care Act, most notably in dropping the legal requirement for commissioners to put services out to competitive tender.

KONP and other campaigners have supported moves to scrap competitive tendering, while stressing that, in the absence of wider legislation to roll back the 2012 Health & Social Care Act and reinstate the NHS, such moves would not be sufficient to end privatisation or the fragmentation of the health care market.  We expressly stated the following:

“KONP will continue to press with our campaign allies We Own It and others for the repeal of Section 75. But, unlike NHS England, we seek the full repeal of the rest of the 2012 Act and scrapping a market system that has delivered no benefits but has added major costs and many other problems since it began under Margaret Thatcher.”

However, we have now had eight months of government using emergency powers related to the Covid pandemic to allocate tens of billions in contracts with no competition or public scrutiny – and we have seen just how disastrous contracting without competition or regulation can be.

And NHS England is pushing forward with ever bigger and more wide-ranging “framework contracts” confirming that they want to change the process but are firmly committed to more privatisation.

If such proposals are brought forward again we should not support them: with or without competition regulation, carving up the NHS into contracts does nothing to integrate services and only serves to benefit the private sector. The only satisfactory way to amend the requirements for commissioners to put services out to tender would be as part of a process of bringing all outsourced services back in-house, and scrapping the costly and wasteful purchaser-provider split.

It’s quite possible that one reason for ministers’ reticence over the proposed legislation to tweak the 2012 Act is that discussion of competitive tendering could open up further public discussion and scrutiny of the contracts that have recently been awarded in an environment of naked cronyism.

NHSE is proposing the formation of joint committees so that an ICS could make legally binding decisions in a joint committee with their CCG. Some government sections are arguing to go further and scrap CCGs, replacing them with ICSs – we need to be alert and campaign for all NHS bodies to be statutory and wholly public bodies, with no private interests on the decision-making boards.

The state of play

NHS England has made clear that they aim to ensure the whole country is eventually covered by just 42 ICSs. This was to have been achieved by April 2021, but some areas have been able successfully to stand out against the CCG merger process, so the drive for ICSs will continue in a partial way until the dissident areas can be forced into line. In theory at this point (11 November 2020) there are 18 “Integrated Care Systems” in England, although some of these appear to exist in name only, with little evidence of any activity.

The ICS bodies that have been established so far have no legal standing or authority – and therefore no requirement to meet in public, consult or engage with local communities, or publish board papers or policy proposals. Their websites are almost without exception out of date, tokenistic and devoid of serious content, with almost all meetings taking place behind firmly closed doors, and the few public sessions revealing little of substance.

Whatever influence ICSs may have is exercised behind the scenes, and any decisions they take remain obscured from public view. The few attempts to show the “achievements” of ICSs all cite projects initiated well before the first ICSs were in place, confirming that the possibilities of greater cooperation were already in place given the increasing failure to uphold the principles of the 2012 Act.

The employers’ body, the NHS Confederation, last year raised concerns that ICSs would be too heavily controlled by NHS England, and landed with extra powers and responsibilities without the necessary funding to carry them out.

In January this year the HSJ highlighted the fact that many ICSs were integrated “in name only,” with serious limitations on how far they were prepared to go in practice, not least on finance:

“NHS England and NHS Improvement expect an ICS to have accepted a single control target for its health economy. However, to date only Dorset ICS has gambled all of its sustainability funding on meeting the collective control total.  […]

“Meanwhile, in systems with multiple clinical commissioning groups, some CCGs want reassurance that their five-year funding allocations as already issued will all be spent on their population, even as they come together across a wider patch.

“Some parts of England are happy to work towards a system control total at “place” level — of populations between 150,000 and 500,000 — but are much less keen to do so across their wider ICS, especially where other “places” within have entrenched financial problems.”

It’s clear from this that while NHS England sees ICSs as a device to police tighter limits on spending and force through “efficiencies” and cutbacks as required to eliminate trust deficits, there are tensions that make it unlikely these limits will be any more effective than the cash limits that have applied for the past 45 years to (and been repeatedly breached and widely ignored by) health authorities, NHS trusts, foundation trusts, primary care trusts, and present-day CCGs. Cash limits have proved less powerful than the fear of high-profile service failures whether the funding has been through capitation-based block contracts or so-called “payment by results.”

So although campaigners could try to build public concern by flagging up the danger of cutbacks driven by ICS policing of control totals, it’s only a matter of time before ICSs are as burdened down with deficits as are Trusts, foundation trusts and CCGs.

The underlying issue for campaigners is the need for increased and sustained funding with increases to keep pace with growing population needs – an issue that pre-dates ICSs.  And in the absence of appropriate government action, this issue will continue after ICSs fail and make way for the next organisational fad.

Government view ambiguous

According to the HSJ (September 28) Simon Stevens is expecting new legislation ‘in the first half of 2021’ which will create a ‘legal form’ for integrated care systems.

However, even after NHSE published proposals for an “NHS bill” last autumn ministers have seemed in no hurry to push this through, and the last Conservative election manifesto was evasive, promising only that “Within the first three months of our new term, we will enshrine in law our fully funded, long-term NHS plan.”

This was followed in January by legislation that simply locked down the funding of the NHS for the next five years to the inadequate level proposed by Theresa May’s government at the end of 2018.

It appears that the Johnson government has preferred to continue the previous line of allowing the sections of the 2012 Act to drop by the wayside through lack of enforcement rather than push through legislation. The lack of legal challenges to this suggests that the private sector is quite content for this to continue.

It’s still unclear whether and to what extent, given other priorities for government, ministers support the NHS England’s legislative approach to ICSs: the HSJ suggests that while Matt Hancock was keen to push through legislation quickly, the rest of the cabinet took a different view:

“Government, especially the Treasury, is thought to be keen on going further than NHS England’s original proposals and giving ICSs the status of statutory bodies. This approach would probably lead to the abolition of clinical commissioning groups.”

NHSE’s own proposals suggested a legal status, but did not recommend establishing ICSs as formal statutory bodies, saying this would be an “unwelcome disruption and distraction at this point” – quite possibly because it would focus attention on the question of local accountability and scrutiny.

However the reality is that in many local area CCGs as originally constituted (there were at first over 200 local bodies commissioning care for relatively small populations) have already effectively been abolished by the mergers that have already been pushed through or rubber stamped.

Any legitimisation of ICSs would leave merged CCGs as largely redundant bodies: however unless CCGs’ statutory duties to act as public bodies, publish papers and accounts, consult on changes and respond to local government scrutiny were transferred to the ICSs, their abolition would leave the NHS with no local accountability whatever.

However, with few meritorious exceptions, it has proved difficult or impossible to build substantial campaigns to defend CCGs against mergers which have been accepted in other areas, and it’s most unlikely that once merged former CCGs will be re-created. Campaigning on this issue is no longer possible on a national basis, although local campaigns are right to continue.

The KONP/HCT Rescue Plan argues for the repeal of the 2012 Act (which created CCGs and NHS England) and to:

“reverse the fragmentation that has flowed from [the Act], scrap the regulations that continue to carve up local services into piecemeal contracts, and begin to bring outsourced and privately provided services back in-house.

“Commissioning as it has developed since the “internal market” was established in 1990 needs to be abolished. Instead the function of planning, allocating resources and provision of services should be brought together in unified local health boards, which should be established as accountable local public bodies based on local government boundaries, and working closely with local borough, unitary and county councils.”

ICSs and private sector encroachment

One line of campaigning on ICSs that might prove productive is if sufficient public attention can be focused on the extent to which the Health Systems Support Framework is being effectively used in each area to drive forward the involvement of private companies in the planning and commissioning of health care.

One eagle-eyed local reporter has publicised the role of a Deloitte consultant as a potentially voting “lay member” of the NE London Commissioning Alliance (ICS). If local media could be persuaded to latch on to similar examples of untoward interference by the private sector in the running of the NHS it’s possible some wider public anger could be generated, possibly drawing councillors and MPs into the fray.  This local vigilance is another task for campaigners.

The private sector is increasingly in evidence – although much of its activity is behind the scenes. As the Lowdown (following up on the detailed work by KONP’s Greg Dropkin) pointed out in February, the Framework contracts offer trusts, CCGs and emerging ICSs a list of ‘accredited’ companies who can be brought in to draw up policies and make decisions in place of NHS management. The services on offer are:

Of the 83 suppliers accredited by NHS England to provide these services, 76 are private companies – almost a third of them (23) US-based. Only 7 are NHS organisations. Among the big American corporations are McKinsey, Optum, a branch of the giant UnitedHealth (former employers of NHS England boss Simon Stevens), IBM, Centene, Cerner, Deloitte and GE Healthcare. McKinsey has been influential in the NHS for decades, and Optum has already won contracts for a range of data-based services for the ICS programme.

It’s likely that local news media, with inexperienced and over-stretched journalists seeking to penetrate the cloud of confusing verbiage and PR spin generated by the NHS will be hoodwinked by many of the local schemes. Campaigners would need to work extremely hard to secure and explain enough information on these contracts to get any serious news coverage, without which the vast majority of the local public will remain unaware of how public services are being skewed and public funds diverted into private companies.

Exposing the naked emperor

One avenue is to find ways to publicise the fact that many of these new approaches just don’t work. The Lowdown reported new research in the USA earlier this year which exposed the lack of evidence that costly and complex data-led attempts at “population health management,” or targeting the small number of patients with complex medical and social needs (so-called “super-utilisers” who account for a large proportion of health care costs), can either reduce demand or cut costs.

A study in the New England Journal of Medicine revealed that the “Camden model” (using a multidisciplinary team of clinicians, social workers, community health workers, and health coaches to work with patients in the hospital and then at home, with a primary goal of helping patients stay out of the hospital) had no impact on hospitalisations or associated costs in a 6‐month follow‐up period. And an article In the Millbank Quarterly  argues that:

“The unfortunate reality is that these evaluation results are not surprising at all. Red flags regarding the hype and overpromise of super‐utilizer interventions have been waving for several years.  …

“… The truth is that hot‐spotting interventions are primarily cost‐containment strategies aimed at individual, very expensive patients. They are not interventions aimed at the macro‐ and community‐level systems and institutions that drive social, political, and economic disadvantage and health inequities.”

Similar findings in England have also been ignored for the past seven years by NHS England, who are throwing good money after bad on ill-conceived, privately-led and costly data-driven systems at the core of ICSs, all of which we can already predict will fail to deliver the promised results.

Streamlined contracting out

The drive for privatisation is not confined to back office number crunching. Last December NHS England’s privatisation wing, Shared Business Services, widened the net to include clinical care, inviting providers, including NHS, non-profit and for-profit companies, to apply to be included in a ‘Framework agreement’ for the supply of outsourced clinical services, including Cardiology, gynaecology, paediatric and oncology services. This is intended to make it easy for commissioners to award contracts for various services.

NHS SBS invites various private and other providers to join networks of approved outsourced suppliers, from which the NHS can buy in services without themselves going through a full process of competitive tendering – by simply choosing a supplier from the list (or conducting a ‘mini-competition’ between a few already authorised suppliers.)

In other words it is batch privatisation, aimed at encouraging NHS trusts to outsource services (with the lure of varying possible “discounts”) – or “insource” them, by bringing contractors into Trust premises to deliver services – rather than providing them themselves (and paying staff on NHS terms and conditions.)

This could in some cases mean contracting out whole units or services (and presumably transferring existing trust staff, or making them redundant).

This is at present on a relatively small scale (£117m over 2 years for clinical services, compared with an NHS England budget of around £115 billion) but clearly the aim is for this to be the start of something bigger.

Because SBS conducts all of this procurement and sets up the “framework” of privatisation centrally, allowing NHS bosses to make OJEU-compliant appointments from its lists of 800+ “approved suppliers”, it also ensures there will be even less chance of any local public discussion or consultation of the outsourcing, which might take place if decisions are made through boards or governing bodies which meet in public. This in turn makes it much harder for campaigners to highlight and mobilise against the use of these framework contracts to privatise local services.


There are several aspects of Integrated Care Systems that clearly pose problems that campaigners could highlight and publicise, and in the right combination of circumstances could be the basis for at least localised popular campaigns.

These topics include:

  1. Loss of accountability resulting from mergers of CCGs and trusts, creating larger bodies more remote from and impervious to demands or pressure any local community.
  2. ICSs with new legal powers policing cash limits as “control totals” and forcing trusts or commissioners to carry through cuts, closures and reconfigurations in the quest for cash savings.
  3. Further and increasing restrictions on the range of services provided and covered by the NHS, with growing lists of “procedures of limited clinical value” – forcing more and more patients requiring elective treatment to pay privately or go without.
  4. ICSs forcing through more outsourcing/private provision of clinical care, facilitated by framework contracts.
  5. Private companies and management consultants leading ICSs into more “digital” provision of outpatient and primary care services leaving millions excluded, picking up hefty IT contracts, and data crunching contracts for population health management.
  6. Management consultants and private companies getting seats (and votes) on decision-making committees of ICSs.

The uneven extent of ICS organisation, the variations between ICSs and the varying extent to which ICSs will become a tangible force in local health care mean that it’s unlikely that any one of the above issues will prove relevant or viable as a focus for campaigning throughout the whole of England.

For areas where the CCGs have already merged, and where an ICS has yet to make any decisive moves, many of the issues in the above list will appear abstract and a relatively distant threat compared with the immediate problems of the Covid pandemic, bed and staff shortages, etc.

KONP should produce a general leaflet capturing some or all of the points above and attempting to popularise an understanding of the threats posed by ICSs. While keeping this overview in mind, KONP should seek regular reports from all branches, and urge local vigilance as ICSs take shape and the remaining areas come under increasing pressure to merge CCGs and trusts.

Local KONP groups, with support if required from the National office and campaigns team, should be ready to respond with strong local interventions where any suitable opportunity arises.

Drafted by John Lister

for KONP November 24 2020


[1] ACOs, ACSs: accountable care systems and organisations; ICSs, ICPs: Integrated care systems and providers