VODG responds to NHSE/I Integrated Care Systems consultation

8 January 2021

VODG has today submitted a response to NHS England and NHS Improvement’s (NHSE/I) consultation ‘Integrating care: Next steps to building strong and effective integrated care systems across England’.

The consultation sought views on the NHSE/I document, which details the guiding principles for the future of integrated care systems (ICSs) in England and outlines two proposals for how ICSs could be embedded in future legislation.

Key points raised in the VODG submission, include:

  • The ambitions of integrated care systems (ICSs) to strengthen partnerships, develop provider collaboratives, develop strategic commissioning and harness the use of digital and data are to be welcomed.
  • ‘Integrating care: Next steps to building strong and effective integrated care systems across England’ looks inward to how the NHS wants to organise itself and in doing so fails to engage with the wider agenda of working with the voluntary sector and social care community providers. The current proposals are at risk of repeating previous mistakes in looking internally, and not externally to fully realise shared policy ambitions for integrated services.
  • There should be strong ambitions to forge greater collaboration and partnership working between the NHS and the VCSE sector.
  • There needs to be greater detail around how the voluntary sector and community social care will be integrated into the different ICS models.
  • If partnerships are to be meaningful, “others” referenced in the consultation document must be carefully defined and – crucially – resourced to enable active participation. Governance and budget arrangements must allow partners to direct resources jointly.
  • Achieving good health outcomes for all requires an equal emphasis in collaborative arrangements for the promotion of public health and tackling health inequalities alongside empowering and enabling people, and those who support them, to take responsibility for improving and maintaining their own health.
  • Enabling people to stay well will also require the engagement of those working in housing, environmental health, economic development and the social welfare and benefits system.
  • Compelling evidence and substantial and genuine engagement with the VCSE sector and the general public will be required for the proposal to be accepted at a local level and not regarded as a process of cost-cutting re-organisation.
  • If the commitment to partnership is to be truly meaningful, voluntary sector leadership should be ‘consistently involved’ in ‘place’ leadership arrangements as opposed to ‘flexibly’.
  • It is not enough for the voluntary sector to be represented by local authorities, who are the commissioners and therefore not genuine representatives. Voluntary sector engagement must be a requirement and not a suggestion.
  • Collaborative arrangements must include diverse providers of different sizes to avoid remote and unaccountable concentrations of power.
  • Collaboration should also break down false barriers between commissioners and providers and include a drastic overhaul of commissioning, which has significantly failed to achieve improved health outcomes for the population as a whole.
  • VODG welcomes the provider collaboratives approach being adopted, especially as it relates to specialist disability and mental health provision. VODG believes that approaches that bring together local partners from a range of backgrounds to take control of funding, the design and delivery of community services are much more likely to succeed in the long-term when compared with traditional ‘commissioner/provider’ relationships.
  • The success of relationship-based approaches is likely to be predicated on local people and communities, alongside voluntary sector organisations, being brought in from the outset to co-produce and co-design approaches.
  • Arrangements must ensure that smaller providers are also able to enter collaboratives whilst maintaining their autonomy and independence.
  • Checks and balances will be required to ensure that excessive power and influence is not concentrated in the hands of any such fewer and larger providers.
  • The success of provider collaboratives can be significantly enhanced by harnessing the collective expertise of voluntary sector providers, co-ordinating the delivery of services and working across organisational boundaries. However, transformational change with common purpose and collaborative leadership is required.
  • The voluntary sector can support effective commissioning through the co-design and co-production of services, especially as a means of forging new integrated health, social care and community services. But there are challenges involved which must prompt a fresh approach to how the NHS approaches commissioning and it must refocus based on outcomes and not price alone.
  • Health-based commissioning activities that do not support effective delivery with the voluntary sector should be abandoned – such as competitive tendering and narrow procurement rules – in favour of genuine partnership building.
  • Short-term competitively tendered contracts are a barrier to sustained long term involvement by providers in the partnerships with health services. The ICS proposals should go further and explain how it will deliver a transformed approach to ensure longer term partnerships with the voluntary sector are maintained.

Dr Rhidian Hughes, Chief Executive of VODG, said:

“Regardless of which option NHSE/I decide to take, there are fundamental principles that need to be integrated into the implementation of ICSs. If striving for great care (as well as health) outcomes, we need a system that actively involves and engages disabled people and the voluntary sector.

“By including mandatory membership for the voluntary social care providers, as well as a commitment to co-production, the risk of simply rearranging the existing systems can be avoided and genuine transformative change can be achieved.”

VODG Media Centre