AUKUH raises concerns to NHS Improvement in response to its consultation on a Single Oversight Framework
The AUKUH has responded to the NHS Improvement consultation on a Single Oversight Framework, which brings together previous regulatory frameworks for Foundation and non-Foundation Trusts in England.
AUKUH comprises 30 Foundation Trusts and 14 non-Foundation Trusts in England, plus three healthcare providers in Wales, Scotland and Northern Ireland. Together the membership comprises the largest research and teaching Trusts in the country, and around 60% of the NHS England Specialised Commissioning budget.
We are supportive in principle of a framework which reduces reporting burden and duplication. The proposed framework however reflects a move to a more centralised and interventionist approach to regulation than previously. AUKUH is adamant that the system as a whole needs successful organisations to be free to innovate and lead. We do not believe that reducing local autonomy will help to improve the financial position, standards or quality and performance, or responsiveness to patients and communities. Furthermore, the framework removes the requirements on the NHSI to consult, which could prove counter-productive.
We are deeply concerned that the proposed framework seems to be based on the premise that the provider sector deficit is caused by insufficient financial discipline. Whilst it may seem easy for providers to externalise the problem, it is also too easy for providers to be penalised for issues elsewhere in the system. There is a risk that the different bodies will continue to send different messages about priorities, with the risk of double jeopardy for providers. We ask that the national bodies work together to eliminate this risk, so that providers know clearly what they are aiming to achieve and how they will be assessed in a consistent and objective manner. At this stage, the detail around metrics and thresholds is lacking. A set of clear criteria, and a review process, will be necessary.
AUKUH response to NHS Improvement consultation on Single Oversight Framework