Response to consultation on contracting arrangements for Integrated Care Providers

We have responded to NHS England’s consultation on contracting arrangements for Integrated Care Providers (ICPs). Our response was informed by engagement with our wider membership and interviews with members of our Board, comprised of CCG leaders across geographical constituencies, including lay members, Chief Finance Officers, Chairs, and Accountable Officers.

In our response we raised the following key points:

  • Our members report widespread for the aims of the ICP contract and opportunities it presents, but feel that this should not be the only option available

Potential benefits of the ICP contract are its ability to enable a focus on outcomes and prevention, and the opportunity it affords to commission primary care alongside wider NHS services, public health and social care provision. This has the potential to further integration and the delivery of person-centred care. However, the ICP contract must not be seen as the only option to enable integration, and most of our members do not have plan to use it in the near future. We would like to see a number of nationally approved formal integration mechanisms, in addition to the ICP contract.

  • The ICP contract is not a means to integration – strong local relationships must come first

As a contract is not in itself a means to achieve integration, it must be recognised that sufficient groundwork is first required for local areas to build trust and relationships.

  • A number of implementation challenges will need to be worked through

Some of these relate to accountability and oversight, reflecting the need to ensure appropriate oversight is in place, and to clarify the mechanisms by which commissioners can challenge providers if outcomes are not being met. Other issues to be addressed include the incorporation of primary care, risk and reward sharing, and the inclusion of local authority commissioned services.

  • Within the current regulatory and accountability frameworks, barriers to integrated working will remain

Without revisions to the broader regulatory environment and accountability frameworks within which organisations operate, the ability for organisations to make decisions for the best of the system, rather than just their individual organisations, will be hindered. Approaches to system monitoring and regulation would need to change to facilitate sharing of system risk. Our members also feel that responsibilities for assurance and regulation need changing – a single process that covers all the health and care organisations across a place should encompass indicators that are the sole responsibility of a specific organisation but also indicators that are the responsibility of every organisation across the place, to mandate ‘collective responsibility’.

NHSCC will continue to represent our members’ views as this policy area develops, and will respond to the Department of Health and Social Care’s consultation on Directions for integrated care providers (ICPs), which closes December 7th.  If you would like to feed back any comments to inform our response, please contact Emily Jones, Senior Policy Officer at

Download Consultation response