Are #NHS Integrated Care Systems & whole population budgets fit for purpose? We’re unconvinced say #Bristol #Labour councillors

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November 23, 2018 by Protect Our NHS

As Labour councillors we believe there are far too many concerns and unanswered questions surrounding the implementation of ICP commissioning and we would not be confident for our local authority to participate in this model‘.

So concludes the submission which Bristol councillors on the joint health scrutiny committee of Bristol, North Somerset and South Gloucestershire (BNSSG) have made to Bristol City Council’s Health and Wellbeing Board.

The submission, which has been sent to Julia Ross, Chief Executive Officer of the BNSSG Clinical Commissioning Group (CCG), is a response to NHS England (NHSE) who asked Councils to comment (consultation closed 26 October 2018) on whether they would use the proposed Integrated Care Provider (ICP) contractual framework to jointly commission health and social care services.

The BNSSG CCG is proposing going down this route via its Healthier Together programme.

It’s important to remind ourselves that NHS bodies are not democratically accountable.

And naming a new model for delivering health services Accountable Care Organisations/Systems, or changing terminology to Integrated Care Systems, and Integrated Care Providers, does not alter that fact.

What the councillors stress is important:

We are democratically accountable to the people of Bristol, and therefore must also represent the concerns that local people have shared with us regarding the future of their health and social care services. These include waiting times for referrals, rationing of health care, cuts to social care services, lack of access to GPs, and fears of creeping privatisation in the NHS‘.

They question whether Integrated Care Systems and whole population budgets are fit for purpose, as they do not address:

  • The national under-resourcing of the NHS, with a lower proportion of GDP invested in health compared to other western economies.
  • The lack of a national long term sustainable solution to social care funding.
  • A shortage of GPs and crisis in recruitment in the health and social care sectors.


The submission covers a wide range of issues that reflect the councillors’ knowledge of what’s happening to the NHS and its impact on local authorities. It should be read by other councillors across England.

On public consultation and accountability: 

ICP bodies would lack defined legal status or democratic accountability and oversight. They could potentially take responsibility for the entire local health (and possibly social care) system, in huge 10-15 year contracts, albeit allowed to sub-contract to other providers. Our residents would rely totally on the services they provided, but would lack any meaningful way of influencing their decisions on allocating resources or planning services...

…This model proposes only the most minimal ‘engagement’ with the public, not full statutory public consultation when funding decisions are made

On joint commissioning:

This ICP model for joint commissioning appears to be largely led by the NHS with very limited practical input from local authorities. The LGA was consulted in this process but has no statutory powers. NHSE has not been listening sufficiently to local authorities on adult social care, nor does it reflect in this document the role of elected councillors regarding democratic accountability‘.

On integration:

There are existing mechanisms for integration that seem to have been entirely overlooked by this model. There are important omissions from the ICP proposal document: no mention of Health and Wellbeing boards, community safety partnerships, or safeguarding boards… 

…This proposal appears to be a much more complex way of doing what health and wellbeing boards should already be doing, integrating health services in co-ordination with the ‘population health’ role of the local council‘.

On long term contracts:

There are significant risks in commissioning, managing and monitoring supersize, long term 10-15 year contracts…Who has the responsibility, and most importantly the capacity to monitor the super size contracts to ensure agreed outcomes are being achieved and money well spent? What happens when the provider of one huge contract cannot fulfil the outcomes or goes bankrupt? (We have seen this happen before in other sectors, in the case of Carillion) The risks are far greater when it is vulnerable people relying on health and care services, should anything go wrong‘.

On super-size:

The ICP model of ‘super-size’ contracts is increasing the separation of ‘purchasing’ and ‘providing’ functions. The merging of CCGs to align with large geographical footprints appears to be returning to something similar to a Primary Care Trust model, rather than the more localised provision of a GP led model, offering continuity of care, close to home, that was originally envisaged when CCGs were created‘.

On privatisation:

Is this model opening the door to privatisation? The ICP would be taking on 10-15 year multi billion pound contracts…The contract framework has been written in a way that could apply to private providers. It may be that private providers are the only ones large enough to take on the huge multi billion contracts. This would allow for a drift towards privatisation of health care (immediately or in the future) that many of our residents are very unhappy about‘.

NHS England needs to listen to councillors like these.

Read the full submission here.

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“That’s the standard technique of privatization: defund, make sure things don’t work, people get angry, you hand it over to private capital.” Noam Chomsky

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