Health and Care Bill

Written evidence on the Health and Care Bill submitted by Diabetes UK

(HCB2 0 ).

1) Introduction

1.1) Diabetes is one of the fastest growing and potentially most devastating health crises of our time. Over 4.9 million people are currently living with diabetes in the UKi. Diabetes UK is committed to creating a world where diabetes can do no harm. Our aim is to fund crucial health research, improve healthcare and treatment, and prevent yet more people developing this potentially life-threatening condition 

1.2) Diabetes UK is the UK’s leading funder of medical research for diabetes, and conducts policy and campaigns work to improve the lives and health outcomes for people living with or at risk of diabetes. 

1.3) Diabetes UK’s submission focuses on the importance of public health policy to reduce obesity and prevent people from developing type 2 diabetes, reducing health inequalities and the need to go further to address the workforce crisis.

1.4) The aims of the Bill states that it will enact policies outlined in the White Paper ‘Integration and Innovation: working together to improve health and social care for all’. The White Paper states that a major reason behind the need for change is the growth of long-term health conditions. As diabetes is one of the most prevalent long-term health conditions, it is important that the Bill works to reduce harm from diabetes.

1.5) The Health and Care Bill represents a timely opportunity to prioritise the population’s health, invest in early intervention and tackle health inequalities. The prevalence of diabetes and its rapidly growing nature means that if the Government uses this moment to make diabetes care and prevention a priority, it could transform the landscape for healthcare and help more people live well.

2) Diabetes is serious and must be a priority for government


2.1) 1 in 14 people in the UK has diabetes and the number of people diagnosed has doubled in the last 15 years. A large part of the rise in diabetes is due to the growing rate of type 2 diagnoses. Diabetes UK estimates there are more than 13.6 million people at increased risk of type 2 diabetes in the UK right now.


2.2) Diabetes is a serious condition and can lead to devastating complications. Every week diabetes leads to more than 185 amputations [1] , 770 strokes, 590 heart attacks and more than 2300 cases of heart failure [2] . Too often, these are avoidable through better care and prevention. Findings show that d iabetes also accounts for 10 per cent of NHS spending, the majority of which is spent on treating these complications, which demonstrat es the importance of preventing diabetes and improving care , not only to improve people’s health , but to eas e the strain on the NHS and build resilience.


2.3) The pandemic has highlighted just how serious diabetes is ; data from the first wave of the pandemic sadly showed that people with diabetes accounted for one in three deaths. The scale and  severity  of the condition means people with diabetes should be considered at the heart of the Government’s plans to reform the NHS.


2.4) T he plans for g reater integration set out in the Health and Care Bill could bring huge benefits to people living with diabetes , paving the way for more joined-up care , and the inclusion of measures to restrict advertising of less healthy food and drink will help to create a more healthy food environment and prevent people from developing type 2 diabetes.


3) Provisions on advertising of less healthy food and drink – Section 123 and Schedule 16

3.1) Diabetes UK is pleased that the Government has committed to act now and tackle obesity. Around two thirds of UK adults are classified by BMI as being in the overweight or obesity categories. Living with obesity or overweight increases a person’s risk of developing type 2 diabetes – it accounts for about 80-85% of their risk. It is therefore imperative that action is taken to create a more supportive environment for healthy living and reduce obesity.

3.2) Diabetes UK supports the provisions in the Bill to restrict the advertising of products high in fat, sugar or salt (HFSS) in Section 123 and Schedule 16 and believes these must not be diluted. Research shows that children are exposed to over 15 billion adverts for HFSS products online every year [3] . Restricting online adverts for HFSS products that contribute to children’s excess sugar and calorie intake, could lead to UK children (aged 4-15) eating 12.5 billion fewer calories a year. That’s equivalent to reducing consumption of 62 million doughnuts a year.

3.3) This reduction will not be spread equally amongst children as some are exposed to far more advertising than others. Evidence also shows that children who already have a weight classed as overweight or obese eat more in response to advertising, [4] so will benefit more from the new rules.

3.4) Children with obesity are five times more likely to become adults with obesity [5] , increasing their risk of developing a range of conditions including type 2 diabetes. New data has also shown that in England, 1560 children and young people (18 and under) are already living with type 2 diabetes [6] . The advertising restrictions in the Bill are an important step to make it easier for everyone to make healthier choices. The Department of Health and Social Care estimates that the policy will lead to health benefits worth £62 million, with social care savings of £49 million [7] .

3.5) We are also pleased that changes to labelling laws in the Bill will make it possible to strengthen nutrition labelling requirements and we’re urging the Government to push ahead with these changes and use the new powers as soon as possible to mandate use of front-of-pack nutrition labelling. There is solid evidence to support interventions to improve the food environment and these should be implemented without delay.

4) Reducing inequalities – Section 14Z35

4.1) Diabetes does not affect everyone equally. Incidence of type 2 diabetes has been found to be associated with lower socio-economic status; and those from South Asian, Black African, and Black Caribbean backgrounds are two to four times more likely to develop the condition, frequently at a lower age and BMI, than White Europeans.

4.2) We know also that inequalities exist in access to diabetes care and treatment. For example:

4.2.1) Data from 2020 shows major inequalities in the number of people accessing the eight care processes that help to monitor diabetes and detect complications at an early stage. Missing out on these vital checks could mean complications go undetected and people miss out on the treatment they need.

· There was a 17.7% difference in the number of people accessing all eight care processes between people from ethnic minorities compared to those of White ethnicity.

· There was also a stark difference according to deprivation: for the most deprived quintile compared to the least deprived quintile there was a difference of 8.8%.

4.2.2) The National Paediatric Diabetes Audit (NPDA) has also revealed a six-year trend of widening inequalities in the care of children and young people with type 1 diabetes in England and Wales.

· In 2019/20 the percentage of Black children with type 1 diabetes using continuous glucose monitors (CGM) is 11.7% and for insulin pumps 26.7%, whereas for White children these percentages are close to double at 20.2% and 39.8% respectively.

· The gap between children using an insulin pump in the most and least deprived areas has widened from 7.9% in 2014/15, to 12.6% in 2019/20.

4.3) Despite previous legislation placing a duty on key bodies to have regard to the need to reduce inequalities, the evidence shows that much more work is needed. So, whilst Diabetes UK welcomes the inclusion of a new duty for Integrated Care Boards to reduce inequalities between patients with regards to access to services and health care outcomes in the Health and Care Bill, this must be backed up by clear guidance which includes the provision of data standards to ensure accountability and transparency. The legislation requires Integrated Care Boards to "have regard to" reducing inequalities which is open to interpretation. Therefore, to underpin this work, quality data needs to be available for local systems to use to remove the barriers that cause structural discrimination, variation and inequalities in diabetes outcomes. To ensure sustained progress is made, Integrated Care Systems (ICS) Boards should also be required to assess the impact that they are making in reducing inequalities in their Annual Reports and NHS England should also assess ICSs against guidance to ICS Boards in this area.

4.4) Tackling the inequalities in diabetes outcomes experienced by those from deprived communities and those from ethnic minority groups, both for those already living with diabetes and those who are at increased risk of developing type 2, must be a priority at both a Government, national NHS England and local level.

5) The importance of data

5.1) The importance of data in tracking the impact of the legislation goes beyond reducing inequalities. Data sharing has benefits for individuals and for supporting innovation in the NHS. The legislation must work in conjunction with the National Data Strategy. We expect any legislative changes to be subject to proper consultation and believe that this will be crucial to maintaining public trust around the collection, sharing and use of their health data. We also hope that clear statutory guidance will accompany any legislative changes, particularly in relation to data standards, outlining a clear expectation that interoperability of data sets is the norm and not the exception.

6) Workforce - Section 33

6.1) Diabetes UK supports the call made by the King's Fund, Health Foundation and Nuffield Trust for a new duty on the Secretary of State for Health and Social Care and Health Education England to publish regular workforce supply-and-demand projections to highlight where action is needed to avert a deepening of the workforce crisis. Section 33 on the need to "report on assessing and meeting workforce needs" falls well short of what is required to properly identify the staffing shortfalls and support the system develop the future health and workforce our nation needs. We support the sector calls for the Bill to go further.

6.2) We are grateful to healthcare workers throughout the NHS who have worked tirelessly over the last year to deliver care under unprecedented circumstances. Supporting the workforce to deliver better care is essential in building a system that works for people with diabetes and transforming the healthcare landscape. Our Diabetes is Serious campaign calls for investment into the workforce across primary care, specialist and inpatient diabetes services, and mental health care. In order to meet rising demand, the workforce across all of these areas requires development and expansion in order to improve outcomes for people with diabetes, and in turn reduce the impact that dealing with devastating and costly complications has on the NHS.

7) Conclusion

7.1) The coronavirus pandemic has exposed the UK’s stark health inequalities and given renewed focus to improving the UK population’s health. With over 4.9 million people already living with diabetes and a further 13.6 million people at increased risk of developing type 2, diabetes must be at the heart of plans to transform the NHS. This must include stronger provisions to reduce health inequalities and further investment into the diabetes workforce.

If you would like any more information, please contact Izzy Roberts, Senior Public Affairs Officer

[1] National Cardiovascular Intelligence Network (2020), Footcare Activity Profile, 2016–19.

[2] NHS Digital (2019), National Diabetes Audit 2017–18 – Report 2A: Complications and Mortality.

[3] McKinsey & Company (2014). Overcoming obesity: An initial economic analysis.

[4] Russell SJ, Croker H, Viner RM. The effect of screen advertising on children's dietary intake: A systematic review and meta-analysis. Obes Rev. 2019 Apr;20(4):554-568. doi: 10.1111/obr.12812. Epub 2018 Dec 21

[5] Simmonds M, Llewellyn A, Owen CG, Woolacott N. Predicting adult obesity from childhood obesity: a systematic review and meta-analysis. Obes Rev. 2016 Feb;17(2):95-107.

[6] Young People with Type 2 Diabetes 2019-20, National Diabetes Audit, National Paediatric Diabetes Audit . Accessible at: Young People with Type 2 Diabetes, 2019-20 - NHS Digital

[7] Department of Health and Social Care/ Department of Culture Media and Sport (2020). Evidence Note. Accessible at:



[7] Monday 23 rd August 2021.



Prepared 15th September 2021