ICS Design Framework welcome but concerns remain

Commenting on the newly published Integrated Care System (ICS) Design Framework, Lou Patten, ICS Network director at the NHS Confederation and chief executive of NHS Clinical Commissioners, said:

“We welcome the publication of the ICS Design Framework as an important next step in the development of systems, as it offers some clarity on the overarching framework for ICSs and examines how the expected legislation should be put into practice.

“This includes in key areas such as place-level working, workforce transition and finances. Crucially, ICSs will also have autonomy in many areas in order to structure arrangements according to their own local circumstances.

“We are pleased key issues have been addressed, including on professional and clinical leadership, which the framework states ‘should reflect the learning and experience gained from CCG clinical leadership, building out from this to reflect the rich diversity of clinical and care professions across the wider ICS partnership.’ It also further outlines the crucial role of primary care in system working, acknowledges the importance of the VCSE sector in provider collaboration and reinforces the continuation of national spending commitments such as the Mental Health Investment Standard.

“However, we do still have a number of concerns about aspects of the framework. These include the continued description of a partnership and an NHS body as the two statutory component parts of ICSs, yet with the expectation that partnerships will operate as forums and be established as a committee rather than a corporate body. As this part of the ICS is about the wider integration of health and care, there is a real risk of the partnership being perceived to have a far more diluted role than the NHS body. We will work closely with the LGA, DHSC and NHSE to support the development of guidance that offers members clarity of accountability and functions for this vitally important part of ICS governance.

“We are also concerned that if, as expected in the forthcoming legislation, the Secretary of State is given increased powers to intervene in local service reconfigurations, systems and provider collaboratives could be reluctant to develop and embrace more innovative approaches to the delivery of services, if there is a risk that defining decisions are taken centrally, not locally.

“It is important to acknowledge the current uncertainty for many board level staff, including CCG, ICS leaders and chairs, and it is vital that the appointments process for ICS chairs, chief executives, executive and non-executive positions is open, fair and transparent. While we recognise this process will take time, current leaders must be properly supported to continue the work required to establish statutory organisations that are fit for purpose by April 2022.”