STPs and Accountable Care roundup
Hempsons is pleased to bring you the latest in its series of news updates on STPs and accountable care.
1. What’s next for accountable care?
Simon Stevens has announced the first eight accountable care systems which are:
- Frimley Health
- South Yorkshire and Bassetlaw
- Nottinghamshire, with an initial focus on Greater Nottingham and the southern part of the sustainability and transformation partnership
- Blackpool and Fylde Coast, with the potential to spread to other parts of the Lancashire and South Cumbria STP at a later stage
- Luton, with Milton Keynes and Bedfordshire
- West Berkshire
It is now understood that these ACSs have signed MOUs with NHS England which require them to develop a ‘pathway’ for STPs in other areas to follow.
The ACSs must meet stringent quality, finance and governance demands in order to be able to adopt ‘full ACS status’ for 2018/19. They must have effective collective decision-making structures.Transformation funding will not be released until each ACS confirms who is accountable for delivering value for money.
Jamie Foster, Partner at Hempsons, comments: “It is clear that accountable care is the only game in town. STPs all over the country are now developing accountable care models and they will hope that the first eight will develop clear pathways for them to follow. One of the most complex issues will be how accountable care systems demonstrate accountability for quality and value for money in a regulatory and oversight regime directed at individual organisations”.
Hempsons and NHS Providers have co-produced ‘A Seven Step Guide to Accountable Care’ which offers practical tips to delivery of accountable care.
Read our new guide to accountable care here
The CQC has now issued its response to its consultation on the next phase of regulation (consultation 1) and opened a further consultation (consultation 2). Consultation 2 builds on consultation 1 and sets out a number of proposals relevant to the development of accountable care models, including in relation to how CQC will:
- regulate primary medical services and adult social care services
- improve the structure of registration, and clarify the definition of registered providers
- monitor, inspect and rate new models of care and large or complex providers
Key points to note are:
- The consultation includes proposals to extend registration to all organisations which have ‘accountability’. For this purpose, CQC defines accountability as:
“Accountability (either directly or through other legal entities or contractual arrangements) for the carrying on of regulated activities, where that direction or control has the effect of rendering the organisation accountable for the quality and safety of those activities, even where responsibility for delivering care sits with others.”
This is significant as it will bring into the scope of regulation organisations which may not directly provide services but which are intermediate or parent companies which exert significant influence over the quality and safety of services.
This will have obvious implications for private sector providers including potentially their investors but, in the context of developing new care models, may well also be relevant to joint ventures and other accountable care structures.
- For complex providers (organisations that deliver services across more than one sector) CQC plan to coordinate monitoring activities and combine information about their services, including by identifying a single CQC relationship-holder who will be the main point of contact between CQC and the provider. CQC plan to take this approach to ACSs and propose to test this in a small number of areas during 2017/18.
- A new approach to provider-level assessment is planned, including for a wider range of providers than currently including corporate providers, large-scale GP providers and new care models
- CQC proposes to improve the approach to the way in which it monitors, inspects, rates and takes action to encourage improvement in primary care services, including for GP out-of-hours and urgent care services, primary medical care delivered online and large scale models of primary care provision such as GP federations, super practices and multi-speciality community providers
- CQC also proposes to improve the approach to the way in which it regulates adult social care.
The consultation closes on 8 August 2017.
The consultation builds on reports that CQC will begin carrying out targeted inspections of some integrated health and social care systems in November. The 2017-2019 Integration and Better Care Fund Policy Framework published by the Department for Health and Department for Communities and Local Government stated that the CQC would be asked to carry out targeted reviews of local health and social care systems in a small number of areas. These reviews are to focus on the interface of health and social care (but not covering wider council social care commissioning) and it has been reported that reviews of the first 20 areas will start in November.
Jamie Foster, Corporate Commercial Partner at Hempsons, comments that “It is welcome news that the CQC is adapting to reflect the evolving NHS landscape in which STPs are looking to put in place accountable care systems and organisations. Moving to whole-system and ‘accountability’ regulation poses challenges that will need to be addressed, but it is clear that the CQC is already developing a new approach in the way it reviews integrated health and social care systems”.
A second major NHS devolution deal is going ahead, with the aim of going live in April 2018. The Surrey Heartlands clinical commissioning groups have signed an agreement with NHS England, NHS Improvement and Surrey County Council.
A share of transformation funding, anticipated to be worth around £80 million in 2017/18, is included in the agreement.
The first area to receive such a deal was Greater Manchester, whose delegation arrangements went live last April. There are some “devolution” arrangements in Greater London but these do not involve significant delegation of powers or budgets.
There is consensus that governance for STPs is complex and challenging. One of the less high profile governance issues is that of the role of CCG lay members and Trust non executive directors in STP governance structures. Their skills and expertise can and should be used to achieve good governance and accountability in the STP process.
NHS Clinical Commissioners and NHS England have produced a useful briefing which brings together ideas about this from some recent workshops. The briefing includes examples of how lay governance groups can input into STP planning and a list of useful actions to support their role in the process. (Briefing here)
In relation to this and other governance issues please see the updated version of our report, Governing for transformation: STPs and governance, produced in partnership with NHS Providers.
The report sets the context for STPs, identifies the challenges for organisations, examines the role of the board, and addresses the constraints of current legislation.
Access our Governing for transformation report here
5. Integration Resource Centre
Hempsons’ Integration Resource Centre contains a series of articles and in-depth reports on new care models, integration, STPs and governance.
Have a browse through the available topics and contact us if you have any questions.