Health and Social Care Bill

Memorandum submitted by Dr A Talbot-Smith (HS 35)

Summary of Submission:

Ø The Health and Social Care Bill removes Public Health Expertise from the NHS, reducing the ability of GP consortia to develop and commission cost-effective solutions to local issues

Ø The Department of Health’s own impact assessment on the Public Health white paper recognises that moving Public Health into Local Authorities will reduce the cost-effectiveness of NHS commissioning [by removing HealthCare Public Health from NHS Commissioning].

Ø Where does the specialty of ‘Healthcare Public Health’ figure in these reforms, particularly at a local level.


1. HealthCare Public Health is a recognised sub-specialty of Public Health Medicine, and forms one of the three core elements of Public Health Practice as defined by the Faculty of Public Health and outlined in the Public Health White Paper "Healthy Lives, Healthy People".1

2. The specialty of HealthCare Public Health constitutes an essential component of NHS commissioning, providing the evidence base on clinical effectiveness and cost-effectiveness for local commissioning decisions, and enabling the development of local solutions to service development and re-configuration.

3. Healthcare Public Health provide the local ‘grass-roots’ advice/input on the clinical effectiveness and cost-effectiveness of interventions and models of care. This advice enables clinicians to develop effective and cost-effective care pathways and commissioning decisions that meet local needs. In my own and many other area’s we work in partnership with GP practice based commissioners, with clear benefits obtained from integrating the evidence base (Public Health) with clinical knowledge (GPs).

4. This is a ‘bottom-up’ relationship, that occurs at the inception of commissioning decisions, and at a very local level in order to be effective.

5. The role of Healthcare Public Health has not been mentioned in any of the recent policies/reform, despite being an integral part of NHS commissioning.

6. The Department of Health’s own impact assessment of the Public Health White Paper recognised that moving Public Health into Local Authorities will reduce the cost-effectiveness of NHS commissioning. This will reduce the ability of the NHS to improve health outcomes, and/or increase the resources required to maintain current population health outcomes.

7. The solutions offered in terms of mitigation are at a very strategic level – ‘perhaps‘ through NHS Commissioning Boards or through Health and Well Being Boards. 2

8. There is no identification of how the operational ‘day to day’ work undertaken by Consultants in Healthcare Public Health (as opposed to Directors of Public Health) will be formally, and more importantly consistently, provided to GP commissioning consortia at a local levl. This activity is vital to ensuring that that evidence base relating to clinical and cost-effective solutions is embedded into NHS commissioning at the inception of decision making.

9. It seems as though national policy, and the DH impact assessment of the Public Health white paper, has been undertaken without a true understanding of the grass-roots, local level, input made by Consultants in Healthcare Public Health to NHS commissioning – and in my own PCT this includes the commissioning undertaken by practice based commissioners.

February 2011


1. Healthy Lives, Healthy People White Paper: Our strategy for public health in England.

2. Healthy Lives, Healthy People. Impact Assessments. Pp 16, para 22. and 23.