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We have responded to the consultation on proposals to put integrated care systems (ICSs) on a statutory footing in the following terms.

"The Richmond Group of Charities is pleased to have the opportunity to comment on NHS England and Improvement’s proposals for the next steps in the development of integrated care.

The Richmond Group brings together a range of major national charities who are all key players in England's health and care system, investing many millions as significant delivery partners for the NHS and other public services. Together we hear the concerns of and provide information and advice to 13 million people each year. Our purpose and credibility flow from the shared insights we generate from our substantial individual contributions, through direct service delivery by our own staff and volunteers, our support for NHS services and staff, our listening to and championing the voices of patients and carers, and our funding for research. We are focused particularly on the needs of people with long-term physical and mental health conditions - especially multiple conditions.

Better outcomes for people are what matter most to us, so we have been strong supporters of the moves towards a truly integrated approach over the past few years. Truly integrated systems and partnerships have enormous potential to pull services and support together around individuals and communities who need them, as well as to make the necessary progress on tackling health inequalities and improving population health. We strongly believe that our national member charities, together with the wider national and local voluntary and community sector, can and should be key strategic partners in this work.

Some of the technical provisions being proposed will make more difference to other organisations than to us, so while we do have some comments and questions, the fundamental ambitions sitting behind your technical and governance proposals are what most interest us and what we support.

We remain convinced that the ambitions and priorities of the Long Term Plan are the right ones, and we were a signatory to a joint letter in Autumn 2019, supporting NHS England and Improvement’s intended approach to legislative proposals designed to improve implementation through ICSs. We support the direction of travel you are now proposing, recognising the significant shifts in culture and practice in local systems that the pandemic has driven, and noting your explicit intention to avoid disruption to NHS staff.

Structural change alone cannot take us all the way to the integrated future we collectively aspire to. We remain concerned to ensure that systems are properly funded and staffed to deliver effectively, including through partnerships with local government, that the relationship with social care is taken fully into account, that people and communities genuinely drive and shape the planned changes, and that the VCSE sector’s contribution is used fully at the centre of planning and delivery rather than at the margins, where it can make less difference. We agree that the overall shape of the structural and governance changes you are proposing would represent important progress but they would be strengthened by building in mechanisms to ensure involvement of non-statutory providers including the VCS and to maximise the impact of the various channels through which patient and public voices can be heard.

We note and welcome the continuing evolution of system leaders’ thinking - and NHSE/I’s reflection of it – in relation both to voluntary sector partnerships and to building community engagement into systems’ planning and delivery mechanisms. As you take steps to implement your proposals, we will be keen to work with you to support local systems to emulate those who are already making strides in these areas, and to go further, making VCSE partnerships strategic and equal as well as developing genuine co-creation and co-design with people and communities.

We also welcome the important recognition of the role of place and the principle of subsidiarity running through your proposals, though we are keen to see more detail, as this work progresses, on the role of and relationship with primary care networks.

We understand the logic of your proposals to devolve commissioning currently undertaken nationally but would like to understand more about the intended relationship between national and local policymaking. To take cancer as an example, commissioners and providers are currently strongly guided by national decisions and structures, involving a strong voluntary sector presence. Thought will need to be given to ensuring that system-level forums do not unintentionally exclude input and expertise from smaller charities.

A number of our members are concerned to avoid moving backwards on the progress made by some national programmes and the potential in others, as well as about the practical implications for existing, well-established mechanisms such as Cancer Alliances, clinical networks or the emerging regional respiratory and integrated stroke delivery networks and the potential for even greater fragmentation in relation to conditions without the architecture of an established alliance/network or concerning multiple conditions. There will remain a need for the national NHS offer, whether in relation to service provision or to volunteer and community engagement, to be clearly articulated. There is a real need to avoid unintended consequences and we will be keen to work with you to reduce these risks.

Overall, we agree that putting ICSs on a statutory footing from 2022 would provide a positive basis for a wide range of long-term developments, and that your second option would provide greater clarity than the first. We also support in principle the proposed permissive approach to local governance arrangements, within a clear overarching framework. NHSE/I would, however, have an important responsibility to maintain an overview of the effectiveness, appropriateness and transparency of locally-determined governance systems. It will be crucial to success that local government is able to play a full and effective role in statutory ICSs and we urge you to accelerate your efforts to ensure that those relationships are strengthened rather than unintentionally weakened by the new statutory approach. The overarching framework should also ensure consistently effective engagement between ICSs and the national and local voluntary sector. We will be keen to engage with you on these issues as the detail of your proposals develops.

During 2021 and beyond, we will be exploring how we can develop real strategic partnerships with ICS leaders as they move towards the potential new statutory arrangements and then bed them in. We aim to develop clear offers to make to them, but we hope that, with your encouragement, they will also be keen to come and make asks of us. The pandemic has undoubtedly opened the system’s eyes to the potential of working more consistently with voluntary and community organisations. To harness that potential, we need to make this a permanent relationship of equals, pooling our complementary strengths in the interests of the people we all aim to serve. We are keen to work with you to support and develop ICS leaders’ understanding of these opportunities, to keep people’s needs at the heart of these changes, and to lock in the positive culture change now underway."

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