Insights from the 10-Year Health Plan: the role of Integrated Care Boards in the NHS

The NHS Fit for the Future 10-Year Health Plan (the Plan) was published on 3 July 2025. This article follows on from our earlier article, “The Model Integrated Care Board Blueprint – Key Insights” and our recent series looking at the impact of the Plan on general practice. This article focuses on the future roles of Integrated Care Boards (ICBs), their monitoring mechanisms, their core functions and their interactions with other healthcare organisations.

The Plan confirms that ICBs will be a central component to a more devolved and diverse NHS. Their strategic commissioning responsibilities will play an important role in assisting the government’s goals of tackling health inequalities, improving population outcomes, and promoting innovation in health service delivery.

A new Operating Model for the NHS

Section 5 of the Plan, titled “A Devolved and Diverse NHS: A New Operating Model”, outlines the government’s ambition to deliver a more diverse and devolved health service. It introduces a three-tier structure for health service provision:

1. Service Providers: Delivering patient care locally through neighbourhood and acute health services.
2. Commissioners: ICBs taking on strategic commissioning responsibilities with a focus on reducing health inequalities and building neighbourhood health services.
3. Department of Health and Social Care (DHSC) and NHS Regions: Providing national leadership by setting strategies, allocating funding, and assessing performance.

This restructured approach reflects the Plan’s aim to establish a leaner, more effective NHS, better suited to meet modern healthcare demands.

As set out in the Model ICB Blueprint (Blueprint), the ICB’s core function will remain as strategic commissioners within the system, ensuring services are designed around population need and health outcomes.

The current issues and aims of ICB reform

The Plan identifies the current variation in ICB performance, leading to health inequalities and inefficiencies within commissioning. It aims to address these issues by introducing reforms to improve accountability, cut duplication, and drive performance.

Key aims of the reform:

• Investment in better outcomes: Multi-year budgets and financial incentives will enable ICBs to focus on long-term improvements. Funding will be tied to outcome-based targets, ensuring commissioners and providers are accountable for measurable improvements in healthcare delivery.
• Enhanced transparency: A new Choice Charter will promote transparency by measuring providers and commissioners against clear metrics. These metrics will include patient-reported outcomes, feedback, and experience measures, empowering patients to make informed decisions.
• Efficiency savings:  ICBs will focus on reducing duplication of functions. The current 42 ICBs will be clustered, with a costs cap expected to be introduced in autumn 2025.

To support these changes, NHS England will roll out a national programme to enhance ICB capability, including a new commissioning framework that will underpin future assessments of ICB maturity.

The role of ICBs under the 10-Year Plan

Under the Plan, ICBs will remain central to the NHS as strategic commissioners of local health services. Their role will include longer-term, value-driven decision-making to improve health outcomes and ensure the sustainable allocation of resources. ICBs will be expected to place quality of patient care at the centre of their commissioning.

Key elements of their function will include:

1. Effective commissioning
   ICBs will oversee nearly all local health service commissioning, except for the most specialised services, using multi-year budgets. Commissioners will need to design their delivery plans based on:
   • Population needs analysis to ensure equitable access to services.
   • Engagement with patients and the public to shape outcome-focused commissioning plans.
   • Contract management and competitive processes to incentivise high-quality services and drive change.
2. Provider oversight and quality assurance
   ICBs will hold responsibility for commissioning neighbourhood health services from diverse providers, including NHS organisations, independent providers, voluntary organisations, and social enterprises. They will also take action to decommission services or terminate contracts where providers consistently deliver substandard care.
3. Pooling resources for scale
   ICBs will have the flexibility to pool commissioning arrangements, facilitating large-scale procurement and the development of provider networks or chains to achieve enhanced service delivery.
4. Encouraging innovation
   ICBs will be empowered to foster a diverse provider landscape that supports creativity and innovation. This approach moves away from traditional service structures, enabling, for example, GPs to manage hospitals, acute trusts to provide community care, and nurses to lead multidisciplinary neighbourhood teams. The Plan also confirms that private providers will remain important in reducing waiting times and improving access in disadvantaged areas.
5. Collaborating with local government
   To improve integrated care, ICBs will work closely with local governments. Their boundaries should be realigned to match those of new combined authorities, ensuring closer collaboration with strategic authority regions to enhance alignment of public health goals.

Transfers of ICB functions

The Blueprint references functions that will be transferred from ICBs and the Plan provides clarity on some of these functions.

Functions addressed in the Plan

Functions not expressly addressed in the Plan

The following additional functions are listed in the Blueprint as being transferred to providers, but are not referred to in the Plan:

• Green Plan and Sustainability
• Infection Prevention and Control
• Safeguarding
• Medicines Optimisation
• Pathway and Service Development Programmes
• General Practice IT
• Emergency Preparedness, Resilience and Response (EPRR)

Whilst greater detail is required about how and where these functions will move to, some assumptions can be made. Existing NHS providers such as NHS Trust and Foundation Trusts will have existing expertise and scale to provide these functions. This ties into the objective of providing them with greater autonomy.

Within primary care many of these functions require scale to operate efficiently. It is therefore likely that they will transfer to the Multi Neighbourhood Providers, or be provided by NHS providers commissioned to provide the services across primary care.

The role for the Regions will be limited to high level oversight and assurance such as co-ordinating EPRR or medicines policy.

Care needs to be taken in relation to the development of these functions with a particular focus on ensuring that the contracting and funding structures operate correctly. There is a risk of the services being subject to VAT if not structured appropriately.

For all functions the transition needs to be carefully managed including planning the transfer of staff in accordance with the Transfer of Undertakings (Protection of Employment) Regulations 2006 (TUPE).

Outstanding questions and areas requiring further clarity

While the 10-Year Plan provides significant detail, certain aspects remain undecided or require further guidance, such as:

• Legislative changes: Upcoming legislation will amend governance structures, including the removal of provider organisations from ICB boards. Strategic authority mayors or their representatives will replace local authority representatives. Further information on these legislative changes is awaited.
• Clustered ICB structures and cost caps: Details regarding the clustering of ICBs and the specific cost cap expected this autumn remain unpublished.
• Commissioning framework implementation: While promised, the rollout timeline and operational specifics of the new commissioning framework are yet to be confirmed.

We will continue to monitor these developments closely and provide further updates as the necessary legislation and guidance are published.

How We Can Help

We are closely monitoring the development and implementation of the Plan and its implications for ICBs and providers. We are able to assist by:

• providing legal advice on commissioning frameworks, contracting arrangements, and value-based healthcare principles,
• assisting with compliance as governance changes are introduced, including the legislative removal of provider organisations from ICBs,
• advising ICBs on taking action to terminate contracts with providers consistently delivering poor-quality care, and on implementing robust performance monitoring frameworks,
• advising on collaboration with local government and neighbourhood providers,
• supporting ICBs and providers in developing contracting and procurement arrangements to pool commissioning strategies,
• advising on mergers and clustering arrangements between ICBs,
• providing employment law advice, including workforce engagement strategies and managing redundancies or redeployment.

Contact us