Commissioning reform

The commissioning reform plans involve a radical rethink of NHS commissioning – a move from traditional ‘transactional’ commissioning to a strategic commissioning model based on the development of the integrated care systems (ICS) as a statutory NHS body in 2022. The clear direction of travel set out in the white paper will see clinical commissioning groups (CCGs) and their commissioning functions transition to the ICS, together with a number of NHSE commissioning functions relevant to and operating within the ICS boundaries. 

The full extent of the NHSE functions likely to transfer to the ICSs remains unclear and while there are indications of the likely constitution of the ICS Board, there is so called flexibility in how systems establish and implement arrangements for the proposed ICS Health and Care Partnership. The white paper reinforces the concept of ‘primacy of place’ and that systems will be given the flexibility to determine local arrangements as to delegations to place-based partnerships and provider collaboratives.

All of this creates a level of uncertainty for commissioners, particularly CCGs, over the next 12+ months as they consider how best to ‘future-proof’ the exercise of their commissioning functions so as to embark on the transition from local commissioning entities to a system-wide strategic commissioner. We have already seen a number of CCG mergers take place and plans for further mergers in response to the NHS Long Term Plan and ICS agenda. We have also seen joint appointments effected across CCGs. CCGs are now looking at ways in which they can use the statutory mechanism of joint committees to create an ICS-wide forum for joint and collaborative decision-making, while ensuring that, for so long as they remain separate sovereign statutory bodies, they continue to fulfil their respective duties and functions. Determining appropriate delegations to joint committees and to individual CCG members and officers, and the reservation of powers to CCG governing bodies and statutory committees, will prove challenging during the transition period due to the current uncertainty about the future system architecture. With the development of PCNs still effectively in its infancy, this creates a further challenge for CCGs in ensuring that the local voice of primary care is not lost during the transition. 

Clear decisions will need to be made within each system as to what should be commissioned and delivered at ICS level and at place level. CCGs will be concerned to ensure that there continues to be appropriate representation of place at the ICS level to ensure appropriate and locally targeted population health management and to protect well-established partnership arrangements that may already be operating at place.