Key points

• We welcome the direction of travel set out in the Health and Care Bill which aims to drive closer collaboration and integration across the health and social care sector, helping trusts to build healthier communities.
• While we welcome the move to system working, more clarity on how different parts of the health system will work together is needed. Allowing different systems flexibility in how they frame their arrangements to meet local needs will also be key.
• We are concerned that the legislation opens up the possibility of political interference in the health service by drawing significant powers of intervention and direction to the secretary of state. Maintaining the clinical and operational independence of the NHS is vital to ensuring this complex system can be run effectively.
• Similarly, we are concerned that new powers to allow the secretary of state to intervene in local service reconfigurations, as currently drafted, risk undermining local accountability in the NHS.
• We welcome measures in the Bill to place a new duty on the secretary of state setting out how workforce planning responsibilities are to be discharged but believe this duty needs to be strengthened.
• We strongly support the creation of the Health Services Safety Investigations Body (HSSIB) as an independent statutory entity. However, we are concerned with aspects of the Bill as currently drafted are liable to weaken the boundaries of safe space and the independence of HSSIB
• We are keen to ensure that the new provisions that will give the Care Quality Commission (CQC) scope to assess and rate systems, do not impact on their ability to provide independent assurance - in particular, the secretary of state’s powers to set priorities and objectives for the CQC’s assessments of Integrated Care Boards (ICBs). The existing arrangements, which require CQC to consult the secretary of state, have been successful in providing the necessary assurance so we do not feel there is a need to change what already works well.