Health and Social Care Bill

Memorandum submitted by the Royal College of Physicians of Edinburgh (HSR 51)

1 The Royal College of Physicians of Edinburgh (the College) is pleased to respond to the Committee’s call for written evidence on the Health and Social Care (Re-committed) Bill.

2 The College understands and accepts the need for change given the demands on the NHS at a time of financial hardship and is committed to working with government and other stakeholders to deliver effective change for the benefit of patients and staff. The College welcomes the restated commitment to a comprehensive health service, free at the point of delivery and the accountability of the Secretary of State for securing the provision of services and the activities of national bodies

3 We believe that the vision and many of the high level policy objectives in the Recommitted Bill are very positive, with a return to clinical focus and local operational control, clear patient input and integrated health and social care.  The emphasis on clinical outcomes is also very welcome.

4 However, the College’s previously expressed concerns about the lack of piloting, reliance on poorly developed clinical information systems and the pace and scale of change remain. The College accepts that the 2014 deadline has been relaxed but the effect of the earlier proposals has damaged the infrastructure in SHAs and PCTs such that managing the transition will now be an even greater challenge.

5 The College offers specific comments on:

§ Commissioning and the role of Monitor

§ Quality and Outcomes

§ Public Health

§ Education and Training

Commissioning and the role of Monitor :

6 The College supports the change to "clinical commissioning groups", which will have transparent governance arrangements and responsibility for emergency services and for geographic populations. The strengthened duty to obtain advice and the requirement to include at least one doctor who is a secondary care specialist is strongly supported as is the requirement to promote research and evidence based commissioning. The College also welcomes the strengthened responsibility of the commissioning board for delivering national guidance on commissioning and which will help support national standards

7 However, we remain concerned that with the abolition of SHAs, a national NHS Commissioning Board will struggle to monitor the effectiveness of strategic planning at a regional level to deliver the integrated services required of health and social care providers. It is unclear how this can be addressed effectively through the new "health and well-being boards" within local authorities. We look forward seeing further detail about the accountabilities and relationships between the NHS Commissioning Board, commissioning groups and health and wellbeing boards when they are published.

8 The duties given to the local commissioning groups to contribute to the strategic plans of the health and wellbeing boards in local authorities are welcome and go some way to addressing the College’s previous stated concerns about the lack of detail. However it remains unclear how disputes between commissioning groups and health and wellbeing boards will be resolved.

9 The removal of Monitor’s duty to promote competition is most welcome, with the change of emphasis towards promoting value for money and preventing protectionism where it is aga inst the interests of patients. The measures to prevent "cherry picking" of services and eligibility criteria that exclude groups of complex patients are also welcome.

10 However the College is sceptical that, given the amendments to the initial proposals with increased governance and consultation requirements, the target reduction of 45% in management and adm inistrative costs is realistic. The College looks forward to seeing further detail on the projected efficiency savings from this amended restructuring of the NHS in England .

Quality and Outcomes

11 The College understands that there are no changes planned for the quality and outcomes aspects of the Re-committed Bill. Whilst the College strongly supports the aspiration of rewarding quality improvement through a focus on clinical outcomes, we believe it is fair to repeat our concerns about the ability of NHS information systems (and associated staffing levels) to support these proposals effectively.

Public Health

12 The College previously expressed concern about t he proposals for public health. It remains unclear how local authorities would develop essential public health expertise, including the management of health screening and outbreaks of infectious diseases and how national co-ordination will be delivered, given the proposed abolition of the Health Protection Agency and the National Patient Safety Agency. 

13 The College looks forward to receiving more detail on the proposed new Public Health Service and more specific, non-legislative proposals in response to the recent public health consultation on improvements in quality and patient outcomes and a reduction in health inequalities.

Education and Training

14 The College notes that the UK Government has stated that there will be a careful transition process for changes in education and training, and that further proposals will be published in the autumn of 2011. SHA and Deanery staff play a vital role in planning, commissioning and quality assuring e ducation and training. We share the Forum’s concerns about how their role will continue following abolition of the SHAs,

15 The College is concerned that the complexity of Deanery functions across the UK has been underestimated and that further delay is unsatisfactory for trainees and staff working in the Deaneries. Postgraduate medical training has undergone significant change in the past 3 years and the College calls for stability and reassurance that providers will retain their training responsibilities, given the important relationship between medical training, quality care and patient safety. The College looks forward to receiving more information on how HEE will establish a framework setting out how medical education and training will be planned and provided in England. This must recognise the UK context given the UK wide regulatory framework and the mobility of doctors.

July 2011

Prepared 19th July 2011