We welcome and support the national policy direction to develop collaborative working within integrated local health and care systems. We also acknowledge that the current NHS legislation and regulatory framework does not fully support this direction of travel. We recognise that a complete re-write of the current legislative framework has not, at this point, been judged either feasible or desirable. Therefore we need to consider whether a a set of carefully drafted and targeted legislative changes can help speed up a move to integrated care.

Our response is informed by extensive engagement with senior leaders within NHS providers. Following the publication of the legislative proposals we have sought feedback from trusts through two surveys and an open invitation to comment, receiving around 90 responses. We have held three roundtables with board-level representatives (one of which included input from NHS England and NHS Improvement colleagues).