NHSCC response to NHSEI consultation on the future of integrated care

On behalf of CCGs, NHS Clinical Commissioners has developed a national response to NHS England and NHS Improvement’s engagement exercise Integrating care – Next steps to building strong and effective integrated care systems across England. 

To develop our response, we engaged with around 300 individuals from our membership during December 2020, demonstrating our strength in the representativeness of the national CCG view.  

Key points:  

  • While we understand there was a national pressure to publish the proposals at pace, we were extremely disappointed at the style of the announcement of this paper in late November, which for many CCG staff came via the media and not CCG leadership teams. This is contrary to the principles of the NHS People Plan and caused a lot of distress to CCG staff who are under significant pressure responding to the current pandemic. There must be a strong commitment from NHSEI from this point onwards to providing clear communication and coproduction with CCGs around their transition in the next 15 months. 
  • Our members fully support the development of Integrated Care Systems (ICS) and are already embedded in system working, seeing it as a unique opportunity to raise the collective ambition around population health, address health inequalities and improved outcomes through collaboration across Health and Social Care. 
  • Our members considered both option 1 and 2 and noted benefits and disadvantages in each. The majority of our members felt that option 2 (statutory footing for ICSs) is a positive step forward for the next phase of integrated care and provided a long-term solution, clarity and direction for CCGs.
  • However, in agreeing this position, we have some significant concerns that must be addressed to avoid any negative impact on CCG transition and therefore ICS establishment. These are set out in our full response but include:  

The proposed pace of option 2 is worrying. There must be a smooth transition for CCGs to the new way of working, with as little disruption to CCG staff as possible to offer ICSs the best start as statutory organisations.

CCGs and their staff have a wealth of knowledge, expertise and legacy which must not be lost during transition. We have highlighted particular issues around clinical commissioning leadership, transition of specialised commissioning and equity of spend. 

The move to a statutory ICS under option 2 will change the dynamic between system and place and may be challenging for some areas to manage that tension, particularly around the authority to act. Joint working with local government will be essential and as far as possible, we need decision making as near to citizens as possible. 

We have also contributed to the NHS Confederation’s submission, which represents the views of the organisations that plan, commission and provide NHS services in England. Read the NHS Confederation’s submission here 

8 January 2021

Download Consultation response