Issue: 71
3 October 2018
This occasional newsletter is researched, written and edited by a group of concerned residents in Ealing, West London who want to preserve our NHS. We view the wholesale engagement of private, for-profit healthcare service suppliers as unnecessary, profligate and dangerous. Increased financial funding is what is needed in our NHS – not financial cuts, closure of vital services or privatisation.
Ealing Out Of Hospital (OOH) Services Single Supplier Contract
Ealing CCG has, I think, admitted that it has received three ‘compliant’ bids for this 10 year contract. Allegedly two of the bidders are:
+ Virgin Care, with some kind of association with Ealing Community Voluntary Service
+ West London NHS Trust (until very recently called West London Mental Health NHS Trust). The bid involves Central and North West NHS Foundation Trust and Hillingdon Hospitals NHS Foundation Trust.
ECCG has promised to make some formal announcement about the ‘outcome’ of the bidding process on 5 November 2018. The plan is that 36 OOH care services will be outsourced to one of these three suppliers beginning on 1 May 2019. The initial contract value is £450 million. Over the course of the contract an additional 24 OOH care services might be outsourced to this supplier and the final value of the contract could reach over £1.2 billion.
ECCG has refused to place its business case for this contract into the public domain. With the bidding deadline having past there can now be no commercial confidentiality considerations. Has ECCG got something to hide?
Virgin Care Terminates Elements of Single Supplier, £270 Million Healthcare Services Contract in East Staffordshire
‘Health Service Journal’ has reported that Virgin has terminated large parts of a controversial NHS healthcare contract in East Staffordshire. The contract was awarded in 2015. It was a seven year, fixed price contract. Termination notices have been served for all services for which Virgin is not the direct provider. These services include hospital services, 111 and Out-Of-Hours services. Virgin and the local CCG have been arguing for 18 months. Virgin had asked for £5 million extra funding.
Integrated Care Judicial Review Appeal – Financial Support Needed
On 18 August 2018, the campaigning group 999Callforthe NHS won the right to appeal the failed April 2018 Judicial Review (JR) about Integrated Care. The appeal will be heard before Christmas, but the campaigners need to raise money to cover their costs. Although the Court of Appeal has capped the cost liability, 999CallfortheNHS needs to raise £18,000 very quickly.
You can read the grounds for the appeal and donate money at:
https://www.crowdjustice.com/justice4nhs-stage5-courtofappeal/
If the appeal is successful it’s likely it will make a nonsense of the current public consultation about the Integrated Care Provider contract – as the contract under the microscope might be deemed illegal.
NHS North West London (NWL) Makes a Second Attempt at Extracting £100 Millions from H.M. Treasury for SaHF Building Work
In 2012 NHS NWL launched its ‘at least three year’ Shaping a Healthier Future (SaHF) plans. SaHF would cut costs annually by 4% and would close down four District General Hospitals (DGHs) and their A&E units. No cost savings have ever been announced. After just two of the DGHs and their A&Es were closed in September 2014, A&E performance across NWL immediately plummeted and has never recovered. The two further DGH/A&E closures failed to materialise.
There had been draft SaHF business cases in circulation for three years. The final SaHF ImBC SOC 1 business case finally emerged into the public domain in December 2016. It contained within it a cash-call for building work of £513 million. NHS NWL duly submitted this bid to NHS England and NHS Improvement. In September 2017 NHSE/NHSI (London) rejected the bid on the grounds that the large reduction in emergency admissions postulated were unrealistic. Fairly soon after this rejection the two NHS NWL Accountable Officers resigned.
It has recently emerged that an attempt to submit an updated version of ImBC SOC 1 is underway. Its patron is the new NHS NWL Accountable Officer Mark Easton. We don’t know yet whether as much as £513 million is being asked for again. A copy of this submission has not been offered, as yet, for public viewing. Mr Easton is quoted as saying he expects some response from NHSE/I by November 2018.
Let’s not forget either that in December 2016, yet another final SaHF business case was mentioned in dispatches – ImBC SOC 2. It was, apparently, a business case for SaHF building work in ‘inner’ NWL with a cash-call for £314 million. Here we are 22 months later and SOC 2 was apparently never submitted and has quietly disappeared.
Integrated Care Provider (ICP) Contract Public Consultation
Accountable Care Organisations (ACOs) first caught my eye in 2016. ACOs, an American ‘invention’, involve long term, fixed price care contracts held by a single supplier. The supplier could be a private company. They were touted as the future vehicles for delivering integrated healthcare and social care services. 32 of the 44 STPs published in October 2016 referred vaguely to Accountable Care Organisations/Partnerships as implementation engines for parts of the STPs.
Nothing much happened with ACOs during 2017 except that two Judicial Reviews (JRs) were initiated challenging ACOs. In January 2018, the JR4NHS JR forced the Government/NHS England to commit to a 12 week ACO public consultation. In February 2018 the Government/NHSE decided to rename Accountable Care as Integrated Care. Integrated Care Systems (ICSs) became the new STP implementation vehicles. The two JRs ended in failure, but the 999CallfortheNHS JR was granted leave to appeal on 18 August 2018 and this appeal is yet to be heard in Court (see above).
In spite of the legal uncertainty surrounding the JR Appeal, the public consultation promised in January 2018 began on 3 August 2018 and will end on 26 October 2018. Of course, we have had another name change and the consultation is entitled ‘Integrated Care Provider contract’.
NHSE has made little attempt to list and explain the issues involved or the likely impact on healthcare patients and social care users under Integrated Care Provider (ICP) regimes.
The massive consultation paperwork is only available online at:
Health Campaigns Together has assembled a very informative web page which contains lots of background information on ACO/ICS/ICP. It has also created a well considered set of summary answers to the consultation questions. See:
https://healthcampaignstogether.com/ACOmonitor.php
My consultation response also contains the following points:
+ ICPs will be 10 year, single supplier contracts which will undermine the NHS as the provider of healthcare services and Local Authorities (LAs) as providers of social care services. ICPs will ‘sit above’ NHS Trusts and LAs and will, in effect, commission all care services
+ ICPs will make CCGs redundant – but there are no plans to eliminate CCGs
+ There is no compelling evidence that supports the notion that the integration of healthcare services and social care services leads to better care outcomes
+ No evidence is provided that supports the notion that the single supplier approach results in better healthcare and social care outcomes than employing multiple suppliers
+ The notion that GPs can either work or not work with an ICP is fragile and dangerous .
+ The elephant in the room is that we need to spend more on healthcare services and social care services. The ICP initiative only serves as an unwelcome distraction to these financial deficiencies.
Integrated Care Provider (ICP) London-wide Public Consultation Meeting: Only 12 Members of the Public Attend
On 11 September 2018 in Newington, East London, NHS England mounted a London-wide public consultation event on Integrated Care Provider (ICP) contracts. ICPs are the preferred NHSE vehicles for providing future Primary, Secondary and Out of Hospital healthcare and social care services throughout England. This event was part of the 12 week ICP public consultation which ends on 26 October 2018.
Only 12 members of the public attended this London event. This is out of an adult population in London of over five million. How NHSE can seriously consider this attendance level acceptable is almost beyond belief. When challenged about this clear attendance failure, NHSE’s main speaker Ed Waller pointed out that the event was one of four to be held in England.
Some ICP facts, challenges and omissions thrown up by this event included:
+ 10 year contracts only (the 2016 quoted option of 15 years has been dropped)
+ Not fixed price contracts any more (a change from what we were told in 2016) – budgets will be set annually
+ Single supplier ICPs with potentially lots of sub-contractors
+ GP surgeries could be ICP contractors if they wished – but they don’t have to be
+ No clarity of guidance on VAT issues
+ No evidence was presented which supported the view that the integration of healthcare services and social care services resulted in better outcomes for patients and service users
+ Mental healthcare and mental social care services were never mentioned
+ STPs were never mentioned
+ There was no clarity as to how many ICPs might ultimately exist in England -apparently ICP creation is all done locally by CCGs
+ The population of an ICP will be aggregations of GP lists but there will be geographic limits imposed
+ Local Authorities will buy services from ICPs
+ If the ICP is a private company (and not an NHS one) it will not be subject to Freedom of Information legislation
+ There are potential data sharing problems for ICPs yet to be resolved
+ No hard copy of the consultation paperwork was given to attendees
+ Dudley is clearly the flagship ICP
