Consultation response

Directions for integrated care providers: NHS Clinical Commissioner's response to DHSC's consultation

Concerns raised over the incorporation of primary care into ICP contracts.

14 December 2018

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Potential benefits of the ICP contract will only be realised if proposals are sufficiently worked through.

We have responded to the Department of Health and Social Care’s consultation on directions for integrated care providers (ICPs). This follows our recent response to the consultation on contracting arrangements for ICPs. To inform that response we sought the views of our membership and interviewed members of our Board, comprised of CCG leaders across geographical constituencies. A number of our members raised concerns about the incorporation of primary care into ICP contracts – we reflect these in our consultation response and supplement them with additional feedback we have received on the draft ICP directions.

In our response, we noted that our members are supportive of the underpinning principle behind the ICP contract to integrate care around the needs of a person. However, potential benefits of the ICP contract, for example that it affords an opportunity to commission primary care alongside wider NHS services, will only be realised if proposals are sufficiently worked through. Below we highlight some key comments from our membership that need to be addressed:

  • Engagement and consultation with the clinical commissioning community is required to ensure that the draft directions are fit for purpose
  • Clinical commissioners require clarification over how primary care can be commissioned through the ICP contract
  • There must be a recognition that the ICP contract and accompanying draft directions will not work for all local areas
  • Wider action is required to address the challenges facing primary care – and national policy activity in this area must be aligned