CCG leaders have expressed concerns over the ‘worryingly fast’ pace at which NHS England proposes to hand over CCG commissioning powers to Integrated Care Systems (ICSs).
The proposals, set out in November 2020, outlined two options for placing ICSs on a statutory footing – a statutory committee with an accountable officer that binds together ‘current statutory organisations’ or, a statutory model that brings CCG functions into the ICS.
In response, NHS Clinical Commissioners (NHSCC) said its CCG members favoured option two, but said this had been difficult to consider as it felt ‘less place led, the pace of change was also worryingly fast and the proposals effectively end the current governance arrangements for CCGs’.
Under NHS England’s proposals, option two would see ICSs established by ‘repurposing CCGs’ and would ‘take on’ CCGs’ commissioning functions alongside other duties.
NHSCC added that while it backs its 300 members and agrees that option two is a ‘positive step forward’, there are some ‘significant concerns’ that must be addressed first.
‘Our members have raised significant issues about the timescale and timing for transition under option two and the disruption it will cause. We must ensure that the implementation of option two (if agreed) offers the least disruption possible to CCG staff and their senior teams and offers integrated care systems the best start as statutory organisations,’ it said.
‘The pace of change must also match the readiness and maturity of ICSs and provider collaborations to receive commissioning functions/teams.’
On the first of NHS England’s two options, NHSCC concluded that this was seen to provide a ‘more phased approach to CCG transition’, but could also be ‘extremely confusing in terms of system leadership and delegated CCG powers’.
It added that this option ‘could work well in areas where partnership working is less mature’ – suiting a few CCGs – but many members felt ‘it had the potential to delay what is viewed as an inevitable move to an ICS statutory footing’.
‘Timing both an opportunity and a risk’
Under its proposals, NHS England indicated that it plans for ICSs to have gained a ‘firmer footing in legislation’ by April 2022.
However, CCG leaders said the ‘timing of the announcement and legislative window is both an opportunity and risk’ – it will be ‘helpful to build on the momentum for change that the Covid response provided’, but if option two is accepted then it means ‘a lot to do’ in the next 15 months.
‘For example, there is very little time to establish shadow boards and authorise ICSs to be able to take on statutory functions – held by CCGs,’ the NHSCC document said.
It added: ‘Without focused support for CCGs to transition – we are in danger of repeating the disruption of the 2012 reforms and making our members appear irrelevant when there is a lot of work for them to do in order to transition but also manage the transition of some specific statutory functions i.e., NHS CHC, section 117, EPPR, safeguarding, primary care estates, public consultation and engagement and equalities (to name a few).’
The NHSCC also warned that the ‘wealth of knowledge and expertise’ possessed by CCGs and their staff must not be ‘lost during transition’ and identified several areas of ‘CCG legacy’ that it said should be maintained if the second of NHS England’s two options is agreed.
These included clinical commissioning leadership and the clinical leadership model for population health, public accountability and scrutiny, and independent quality monitoring.
‘CCGs and their staff perform a raft of statutory (and other) functions which are important for population health and if lost will be to the detriment of the system,’ the document said.
‘Option 2 should not be the end of commissioning but a new way of serving our populations.’
The NHSCC also criticised ‘the style’ of how NHS England’s proposal was announced and said knowledge of its existence came to many CCG staff ‘via the media’.
‘This is contrary to the principles of the NHS People Plan and caused a lot of distress to CCG staff at a time when they were under significant local pressure responding to Covid-19,’ the body said.
‘There must be a strong commitment from NHSEI from this point onwards to providing clear communication and coproduction with CCGs around their transition in the next 15 months.’