FSRH consultation response: FSRH and RCOG respond to Parliamentary Inquiry on the Government’s White Paper

The Health and Social Care Committee (HSC) has launched an Inquiry into the White Paper “Integration and Innovation: working together to improve health and social care”, a document outlining the Government’s proposals for reforming the NHS system via new legislation and other proposals for the NHS and Integrated Care Systems (ICSs). In our joint response with the Royal College of Obstetricians and Gynaecologists (RCOG), we focussed on how ICSs and legislative proposals may improve health and wellbeing outcomes in women’s health via appropriate commissioning and accountability arrangements.

Key points and recommendations

• We believe the fragmentation of commissioning responsibilities will likely remain until there is only one, single accountable commissioner for women’s health at system (ICS) and national (NHSE) levels, holding accountability for commissioning and outcomes in women’s health.

• There is consensus across the medical and non-medical healthcare professions that the commissioning and accountability landscape is not fit-for-purpose, with calls for integrated holistic commissioning of women’s reproductive healthcare. We urged the Committee to consider the joint position on integrated Sexual and Reproductive Healthcare commissioning by the Academy of Medical Royal Colleges (AoMRC), Royal Colleges and Faculties, which calls for women’s reproductive healthcare to be more broadly integrated into women’s health pathways in the NHS. 

• We believe the White Paper proposals on clinical leadership are too vague in remit. At national level (NHSE), accountability could be enhanced with the appointment of a National Clinical Director (NCD) for women’s reproductive health or a National Specialty Adviser in Community Sexual and Reproductive Healthcare (CSRH). Alternatively, we would welcome an expanded remit for the NCD for the Maternity Review and Women's Health to cover women’s Sexual and Reproductive Health.

• At system level (ICSs), we would strongly welcome the appointment of a women’s health lead at the ICS NHS Body Board or equivalent structure. We believe it is also crucial that a Sexual and Reproductive Healthcare lead is represented in Health & Care Partnerships’ Boards.

• We believe merging CCGs into ICSs might prove helpful to undo some of the commissioning barriers. However, the question of how the commissioning responsibilities of ICSs and those that stay with NHSE will work and interrelate in practice still remains.

• The White Paper leaves gaps in terms of proposals for the national reorganisation of Public Health. We expect that much of what has been left out, particularly around the future of PHE’s health improvement functions, will be subject to a public consultation and continuous engagement with stakeholders.

• The proposal to create a duty for the Secretary of State for Health and Social Care to publish a document setting out roles and responsibilities for workforce planning and supply each Parliament does not ensure transparency or accountability. We believe that workforce data and planning should be published annually, with a legal duty on a relevant body to do this. In addition, to provide accountability, there should be a legal duty for the Secretary of State for Health and Social Care to respond to that publication annually in Parliament.

Download the full response here

Read the White Paper here