Campaigners call for public consultation on West Yorkshire and Harrogate Integrated Care System

West Yorkshire and Harrogate Sustainability and Transformation Plan Joint Health Scrutiny Committee (phew, a mouthful) is meeting on Monday 30th July at 2pm in Leeds Civic Hall. It is to scrutinise the Integrated Care System that recently developed from the Sustainability and Transformation Partnership, as part of NHS England’s Integrated Care System Development Group.

The meeting is open to the public and NHS campaigners are going to make deputation statements at the start of the meeting. If you’re coming, please try and turn up at 1.30pm for a group photo – with placards, please bring some.

Proposal to set up a statutory subcommittee that can consult with  the  Integrated Care System about substantial service changes

Calderdale and Kirklees 999 Call for the NHS urge the existing discretionary scrutiny committee to agree to this and for the statutory Joint Health and Overview Scrutiny SubCommittee to be set up FAST.

It should then immediately start work with the West Yorkshire and Harrogate Integrated Care System, about a prompt formal public consultation on the whole Sustainability and Transformation Plan/Integrated Care System.

It is clearly a substantial service change. The clue is in the name “Transformation”.

We’re pleased at the suggestion of up to 2 non-voting co-opted members

Campaigners also welcome the proposal that consideration should also be given to the role of expert witnesses to achieve a balanced evidence base.

Last November, Calderdale and Kirklees 999 Call for the NHS asked the Joint Health Scrutiny Committee meeting to consider appointing expert external advisers and offered to send some names. We have recently emailed the Scrutiny Officer the info that  Dr David Wrigley  and Dr Louise Irvine are willing to be external advisers.

The  Protocol for an earlier Yorkshire and Humber Joint Health Scrutiny Committee said the Committee would take evidence from a wide range of opinion – attempts would be made to ascertain the views of the general public.

We think that the current Joint Health Scrutiny Committee should ask  Calderdale and Kirklees 999 Call for the NHS and other members of the  general public to attend meetings to GIVE EVIDENCE as a formal part of the meeting – not just be limited to 3- 5 minute deputations at the start.

That earlier  Protocol also says non-voting members of Joint Health Scrutiny Committee can be drawn from local patient, community or voluntary sector organisations affected by substantial change or variation. We suggest that includes US.

We welcome the governance paper’s clarification of  the Joint Health Scrutiny Committee’s statutory and discretionary scrutiny duties and powers in relation to the West Yorkshire and Harrogate Integrated Care System.

The bit in the earlier Protocol about discretionary joint working suggests a proactive role for the Joint Health Scrutiny Committee, in taking an overview of health services and planning, and then scrutinising priority areas to see if they meet local needs effectively. We think this SHOULD STAY in the governance arrangements for the current  Joint Health Scrutiny Committee.

We agree with the criteria in the earlier Protocol, for the Joint Health Scrutiny Committee to decide what amounts to a substantial variation and substantial development, and think the West Yorkshire and Harrogate Joint Health Scrutiny Committee should keep them.

We think all relevant public services need to be included in the remit of the Joint Health Scrutiny Committee

The Integrated Care System is about integrated NHS, social care and public health services – plus regional economic growth driven by the life sciences and digital technology industries, via work with the Combined Authority and Yorkshire Academic Health Science Network; plus housing and Department of Work and Pensions under “new care models”.

For example, the Integrated Care System Summary refers to:

“development of population health management capabilities to enable a personalised approach to the management of health conditions in the community”.

What does this horrible jargon mean?

Population Health Management involves a targetted approach at both the individual level (on the basis of known individual risk factors, identified from risk stratification of digital patient data) and at population levels (on the basis of known risks in certain populations and communities). It is also referred to as “Prevention at Scale”.

The Joint Clinical Commissioning Committee  has mentioned this is to involve  “industrial-scale behaviour change programmes”. We think these may be delivered through public health schemes – a possible example of a proposed local authority public health service configuration with West Yorkshire-wide implications.

The Local Maternity System is another. It is to commission a range of maternity services – including some delivered by voluntary sector organisations in community hubs. This might well involve outsourced local authority public health and social care services.

We are don’t like  Integrated Care System secrecy and spin

WYH Spinmasterv2

This has been a problem since the start of the Sustainability and Transformation Plan.

But the Local Government Act 1972 and the Freedom Of Information Act 2000 say the scrutiny process has to be open and transparent. And the earlier Protocol says this means that only information that is expressly defined in regulations to be confidential or exempt from public will be considered private.

Integrated Care System collaborative commissioning and service delivery seems to be a legal minefield, so we would like a thorough examination of what information can legitimately be defined as private, and for this to be spelled out in the Joint Health Scrutiny Committee governance arrangements.

Otherwise, effective scrutiny would be impossible.

For example,  the Competition and Procurement Compliance section of the mental health trusts’ Memorandum of Understanding says

“ the Parties understand that in certain circumstances collaboration or joint working could trigger the merger rules and as such be notifiable to the Competition and MarketsAuthority and NHS Improvement/Monitor and will keep this position under review accordingly.
The parties agree not to disclose or use any confidential information which is to be disclosed under the arrangements in a way which would constitute a breach of competition law.”


Quorum, frequency of meetings and make up of Joint Health Scrutiny Committee

We think half the members present is too low a quorum and we think the membership should include North Yorkshire County Council, since Harrogate and Craven District Council are both included in the ICS.

We don’t think meeting 4 times a year is  enough.

The work programme should include scrutiny of all the so-called Integrated Care System “Enablers”

These are:

  • STP Workforce strategy (finally published April 2018 16 months after we asked for it),
  • Best practice and innovation,
  • Digital ways of working,
    Harnessing power of communities, capital and estates,
  • Business intelligence

These constitute significant service change. For example, the increased use of digital technology, patient data lakes and what the Integrated Care System summary  calls “best practice and innovation” are already undermining the clinician/patient relationship.  Algorithms in unevidenced clinical decision tools are substituted for clinician/patient discussion, decisions about appropriate treatment options and GPs’ ability to refer their patients to specialist treatments. There are clear examples of how this would play out in the mandatory national specification for the new Yorkshire and Humber Integrated Urgent Care service and the restrictions to elective care – what the Integrated Care System Next Steps  calls “Planned care and reducing variation”.

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