Feedback sought on legal changes proposed for NHS Long Term Plan delivery

NHS England are seeking changes to the Health and Social Care Act, including the competition rules affecting CCGs, who can sit on their boards and how closely they can work with trusts. We have submitted initial comments to the Parliamentary Health Committee currently considering this, and want your feedback to inform our responses to both the scrutiny Inquiry, and NHS England’s consultation.

NHS England’s consultation closes on 25 April and the Parliamentary Health and Social Care Committee will be considering the proposals through the latter stages of the consultation period and beyond, and are seeking comment on the changes and their impact. The consultation document can be viewed here.

Early comments were requested by the Select Committee by Monday 18 March for consideration during the first evidence session in early April. The early Londonwide LMCs submission can be seen here.

We would appreciate your thoughts and comments on the recommendation to inform our final response. You can provide your response to us via this short form.

If you would prefer to send a response in directly, we would be grateful if you could share a copy with us via info@lmc.org.uk.

Key points from Londonwide LMCs’ summary response

The prospect of investment going directly into frontline care, rather than having it split up into different funds with bureaucratic application processes, is to be welcomed.

However, there are some key concerns about the legislative changes outlined by NHS England as essential in order to deliver their goals as outlined in the NHS Long Term Plan:

Better Value for Money (p7): we are concerned by proposals to revoke regulations made under section 75 of the HSCA2012 and replace them with a best value test. Such a test would not have consideration for staff well-being. See: https://qualitysafety.bmj.com/content/24/10/608 and http://www.annfammed.org/content/12/6/573.full.
Increasing Flexibility (p9): removing NHS commissioners and providers from the scope of the Public Contracts Regulations would allow NHS commissioners to choose either to award a contract directly to an NHS provider or to undertake a procurement process entirely at their own discretion.
Integrated care provision (p11): the assumptions made about future bodies and roles appears to run counter to the developing collaborative approach being pursued by London commissioners and providers.
The NHS working together (p16): we are sceptical about the impact of proposals to amend legislation to enable CCGs and NHS providers to make joint appointments and removing important governance checks when managing public funds and critical decisions.
Shared responsibility for the NHS (p19): we believe that the stated aims should be quadruple and include consideration of staff well-being.
Planning services together (p20): we welcome the goal of coordinated planning but are concerned about progressing pooled budgets until further consultation has been conducted about which elements of primary care budgets might be affected.
Joined up national leadership (p23): the appointment of a single CEO for London’s NHS England and NHS Improvement bodies is one that we welcome.

Last updated : 20 Mar 2019

Data sharing agreement checklist and guidance for practices (21 Aug 2019)

Londonwide LMCS is aware of the increasing complexity and number of information and data sharing agreements (DSAs) and documents which practices are receiving to review and sign. To support practices,...

New CQC guidance section for practices (20 Aug 2019)

In the past 12 months CQC have visited nearly 400 practices in London and found that: 3 were considered outstanding, 300 were considered ‘good’, 57 required improvement, and 23...

Bowel screening update – August 2019 (20 Aug 2019)

NHS England have provided an information sheet to explain the introduction of the faecal immunochemical test (FIT). This replaced the guaiac faecal occult blood test (gFOBt) at the start of...

Tackling social isolation and loneliness to improve health (20 Aug 2019)

Colin Brown, UK Director for Independent Living & Crisis Response at British Red Cross looks at how their expertise will be of use to social prescribing link workers, as they...

Primary care buddying system (20 Aug 2019)

The NHS London Leadership Academy is working with primary care providers to support development in the sector, and to facilitate wider working across the health and social care system. They...

Vaccination update August 2019 (20 Aug 2019)

Hepatitis B in at risk babies Babies born to mothers infected with hepatitis B require a course of hep B vaccination. The first dose is given within 24 hours in...

Londonwide LMCs’ support for Primary Care Network Clinical Directors (20 Aug 2019)

The introduction of the PCN DES means significant changes in the way practices deliver some existing services, and the rolling out of a new range of services. Londonwide LMCs is...

Safeguarding payments and collaborative arrangements (15 Aug 2019)

On 11 July 2019 Dr David Geddes, NHSE/I Director of Primary Care Commissioning, wrote to CCGs and STPs advising that payment for safeguarding activity is not covered by core NHS...

Tips of the month August 2019 (15 Aug 2019)

We provide weekly tips based on common queries which come through to us from London GPs and practice teams. These are shared via social media and collated for...