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Scrapped: Navigating the restructure of the NHS

Scrapped: Navigating the restructure of the NHS
By Beth Gault
27 March 2026



The health system was thrown into uncertainty in March 2025 with the announcement of the abolition of NHS England and 50% cuts to ICBs in a move that promised to reduce duplication and costs across the NHS.

In June, it was revealed that the Government would also scrap over 200 organisations across the NHS for the same purpose.

The organisations set to close include Integrated Care Partnerships (ICPs), Healthwatch England, local Healthwatch branches, Commissioning Support Units (CSUs), the Health Services Safety Investigations Body (HSSIB) and the National Guardian’s Office.

The 10 year plan, published in July, set out more details for this change including a new operating model for the health service, with the aim of making the centre smaller, ‘more agile and focused on developing strategic frameworks and building partnerships’, and changing the role of ICBs to become strategic commissioners.

However, each of these organisations due to be scrapped currently serves a purpose, supporting ICBs in delivering healthcare either in accountability, integration with wider public services, or with commissioning.

So, what are the functions of these organisations and what will the implications of scrapping them be?

Supporting with integration

ICPs were set up under the Health and Care Act 2022 to bring together ICBs and local authorities within the ICS footprint, in a forum focused on meeting the health and wellbeing needs of the population.

An NHS Confederation publication in 2023 stated that ICPs had ‘one important statutory responsibility – to develop, publish and keep under review their integrated care strategy’.

However, the 10 year plan set out a ‘new partnership’ with local government. In it’s latest publication it stipulated that a neighbourhood health plan would be drawn up by local government, the NHS and its partners, under the leadership of health and wellbeing boards. These would also incorporate public health, social care and the better care fund.

As a result of this new arrangement, the plan stated that ICPs would be abolished. This removal of the statutory requirement for ICPs is due to come under a forthcoming health bill, expected to be laid before parliament early this year.

However, despite this change many ICB leaders remain committed to partnership with local authorities through ICPs.

NHS Confederation’s recent State of ICSs survey, published in November, found that a quarter of respondents were likely to keep ICPs on a non-statutory basis, while two in five planned to integrate ICP functions into health and wellbeing boards and work in partnership with strategic authorities.

‘Regardless of structures, ICS leaders are determined to continue the legacy of ICPs in bringing together partners to address the wider determinants of health,’ said NHS Confederation’s report.

Many ICPs have continued to meet, despite their impending removal as a statutory requirement.

Out of the 15 ICBs that responded to the question have their ICPs continued to meet and was there an end date for this, seven say they have continued to meet and that there was no expected end date for these committees.

Another ICB, South Yorkshire, says the ICP has met consistently over the past three years, however future meetings were to be discussed.

Humber and North Yorkshire ICB says it has agreed a ‘new arrangement for the ICP’ which will continue but with amended membership and work plans.

Somerset ICB says it has different arrangements for its ICP, as it operates as a ‘committee in common’ with its health and wellbeing board, known as the Somerset Board. Therefore, the ICB added ‘meetings continue on that basis’.

Suffolk and North East Essex ICB’s ICP will come to an end when the ICB boundaries change in April 2026, it says. However, a spokesperson added that new ICP arrangements for Norfolk and Suffolk were ‘in discussion with a planned launch in early July once local elections have taken place’.

North Central London ICB also says the board will be considering ICP arrangements following its merger with North West London ICB.

However, Lincolnshire ICP last met in July 2025, according to an ICB spokesperson. And in Dorset, ICP arrangements were stepped down in July 2025.

‘As ICPs remain a statutory requirement, our ICP will not be disbanded at this time but we will cease to meet,’ says a spokesperson from Dorset ICB. ‘The work of the ICP will ultimately transfer to the health and wellbeing boards, with a mechanism being established to ensure connection between the ICP membership and the health and wellbeing boards.’

Despite the upcoming removal of the statutory basis for ICPs, there is still a desire to keep the functions and purposes of the committees within the system.

One ICB chair told NHS Confederation in its State of ICSs report: ‘Fundamentally those ICPs were a very good forum for bringing together all of the system partners, and if they don’t exist in the same form as they do now, the NHS has got to come up with some other proposal or structure that means they will actively engage with those other partners and it may be the health and wellbeing boards.’

Support with commissioning

Another organisation facing abolition is CSUs. These were initially established in April 2013 from the remains of primary care trusts and strategic health authorities. This was following the reorganisation of the NHS under the Health and Social Care Act 2012.

They were intended to provide support for commissioning activities, initially there were more than 20 CSUs in total. But their role was changed with the establishment of ICBs in 2022, and they received a new operating model in 2024.

This new model appointed one managing director across all of the four remaining CSUs, requiring them to operate more at scale.

However, the 10 year plan overhauled the role of ICBs to take on a more strategic commissioning role, and to ‘rationalise commissioning support functions’.

‘This will help drive efficiencies and give ICBs the skills they need to deliver strategic commissioning effectively. We will close Commissioning Support Units,’ the plan said.

Jason Bloomfield, chief operating officer at Arden & Gem CSU recently wrote for Healthcare Leader that the window for ICBs to start taking on services currently delivered by CSUs is ‘short’ and requires a phased approach that ‘stabilises, standardises and transforms’.

‘Initially this may mean a lift and drop of existing services, followed by a transformation phase focused on making the service work more effectively within a different structure. These are complex changes. Recognising this at the outset and planning realistic phases will help manage expectations and make the transition more manageable for both ICBs and CSUs,’ said Mr Bloomfield.

Health minister Karin Smyth acknowledged in November that this would ‘directly impact staff’.

South East London ICB told Healthcare Leader it would be launching a staff consultation document about how to manage the structural changes to the NHS, including the changes to CSUs.

‘The ICB is restructuring to reflect the changes set out in the model ICB, model region and strategic commissioning framework documents. This includes changes to the ICP and CSU. Our structures will support delivery of the model ICB and its changed responsibilities,’ says an ICB spokesperson.

‘Our plans on how to manage these changes, including which functions we expect to transfer over time, will be set out in our staff consultation document, which we expect to launch in early March.’

Ultimately the impact of closing CSUs will have varied impacts across ICBs, as the use of them varies across the system. The key concern, as with cuts to ICBs themselves, will be on retaining essential skills.

Sarah Walter, director of integrated care at NHS Confederation, says: ‘In preparing for further change, ICBs are reviewing every aspect of their operating model.

‘This includes exploring opportunities to share functions across neighbouring ICBs, transferring responsibilities to system partners where appropriate, and ensuring they retain the skills and capabilities needed to act as effective strategic commissioners. Leaders are also navigating a complex and uncertain policy environment, including the prospect of future legislative changes.’

Supporting with accountability

Alongside integration functions and commissioning support, the regulatory and accountability landscape is to be reshuffled under the 10 year plan.

This includes changes to Healthwatch England, local Healthwatch branches, the HSSIB and National Guardian’s Office.

Healthwatch England

Healthwatch was initially established under the Health and Social Care Act 2012 to better understand the needs, experiences and concerns of those who use the health service, and then to speak on their behalf.

However, the 10 year plan said the functions of Healthwatch England would be brought ‘in house’ in a new patient experience directorate, while local Healthwatch functions will be brought into ICB and provider functions, and social care functions will be taken up by local authorities.

The local Healthwatch branches recently launched a petition to ask the government to reevaluate its decision to abolish Healthwatch. It received 11,042 signatures before it closed on 7 February.

In the Government’s response to the petition, they said Penny Dash’s review into patient safety found that there were ‘many organisations carrying out reviews and investigations or looking at user experience’ which can lead to an ‘overwhelming number of recommendations’.

However, Healthwatch Surrey says the abolition of local Healthwatch fails to ‘fully consider the impact of losing independent patient voice and scrutiny’.

‘While proposals suggest that the functions of local Healthwatch could be transferred to ICBs and local authorities, there is currently no plan for how independence, transparency or external scrutiny would be preserved,’ says a spokesperson.

Health Services Safety Investigations Body

Other patient safety organisations facing cuts are the HSSIB and the Patient Safety Commissioner (PSC).

The HSSIB came into operation on 1 October 2023 to look at specific cases of incidents of severe harm, while the PSC was established to look at how patients could better report complications from medicines to improve their safety, following a 2020 review by Baroness Cumberlege into patient safety.

The 10 year plan highlighted that ‘over time, these organisations have expanded their scope’. The HSSIB makes systemic recommendations and the PSC has become an advocate for other patient safety topics, it said.

As part of the reorganisation of the NHS, the HSSIB’s functions will move into the CQC to ‘simplify the regulatory landscape’. While the PSC will transfer to the Medicines and Healthcare products Regulatory Agency (MHRA).

HSSIB says it is crucial that HSSIB maintains its independence to conduct impartial investigations in the transition.

‘Throughout this transition, patient safety remains our top priority. Our work to address systemic patient safety concerns continues as usual,’ a spokesperson says.

National Guardian’s Office

The CQC will also take on the function of the National Guardian’s Office, which was initially set up in response to recommendations from Sir Robert Francis QC’s report ‘The freedom to speak up’ in 2015.

It has created over 1,300 freedom to speak up guardians to support workers to speak up if they feel unable to. However, the 10 year plan said the ‘distinct role of the guardian will no longer be required’.

What does the future hold?

The future form of the health service is still taking shape. With the development of neighbourhoods, integrated health organisations, the merging of DHSC and NHS England, and the changing role of ICBs. There is a lot of change still to be worked out.

April should bring some clarity, with some mergers and boundary changes being formalised across ICBs, as will the health bill that will establish the statutory grounding for the changes.

However, the practicalities of changing form and responsibilities are very much still in flux. It will no doubt take time to shift functions across organisations, all amid the threat of redundancy and the risk of losing expertise.

What is clear is the intention of ICBs to maintain collaborative working and the benefits of the outgoing system as they transition to strategic commissioners.

Sarah Walter from NHS Confederation adds: ‘As changes are introduced including to ICPs and Healthwatch, ICBs recognise the importance of continued collaboration with partners across their local systems, including local government and the voluntary sector.

‘ICBs remain committed to developing stronger links with the populations they serve as they take on the role of effective strategic commissioners.’

Once the fog of redundancy and merging has cleared, only then will what is left of the health service be clearer.

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