FSRH consultation response: NHSE's proposals to integrate local authority services within ICPs need to be clearer

FSRH has responded to NHS England’s (NHSE) consultation on the draft Integrated Care Providers contract. FSRH welcomes the initiative by NHSE to introduce an ICP contract and wants to see new models of care developed and thriving. However, NHSE’s proposals to integrate local authority services within ICPs need to be clearer. FSRH is also concerned that the draft ICP contract might not strike the right balance between what should be nationally mandated and the degree of autonomy that local commissioners should have in determining providers obligations. FSRH believes that the national ICP contract must still outline certain types of essential services to be delivered, including complex contraception and other SRH related care so as not to risk patchy provision and reinforce inequalities.

Other key points and recommendations include:

• FSRH experience is that contraception and SRH care need to be more broadly integrated into women’s healthcare pathways in the NHS to meet patient/public need.

• We echo the Health and Social Care Committee’s (HSC) consideration that legal barriers and fragmentation that arose out the Health and Social Care Act 2012 will need to be addressed. 

• FSRH is concerned that there is a risk that the population-based payment approach (WPAP), which would allow flexible redeployment of resources, might leave room for resources being moved away from financing public health interventions.

• Safeguards must be in place for the providers to be able to absorb rapid changes in demand that were initially unaccounted for when the WPAP was decided upon. It is also crucial to consider unmet need when calculating the WPAP; current spend on services does not necessarily mean it is sufficient spending that meets the demand at present, which is the case of SRH services and public health funding generally.

• The ICP contract needs to be more explicit as to what is nationally mandated for workforce development, and commissioners should be required to spell out in their service specifications a requirement for providers to offer training and Continuing Professional Development (CPD) for staff.

Finally, we highlighted the research FSRH is currently conducting into the synergies between community-based SRH and emerging new models of care. Early results reveal clear opportunities, and we offered to share the results with NHSE when the project is finalised in late autumn.

Download FSRH’s submission below.