Today the Government published its formal response document to the consultation process. I was involved directly, taking part in a Consultative session with Paul Burstow at the Liberal Democrats annual conference in Liverpool and in a private session with him later on, and I also helped to frame the official consultation response by Camden Council.
In the published response today Camden get a specific mention -
And the views of Southampton City Council were identical to ours on the need for "compliance" of GP Consortia to follow the Joint Strategic Needs Assessment (or JSNA). The relevant sections in the response paper today are these -
"Some respondents, for example Camden Council, wanted the Government to “require local authorities and health commissioners to pool resources”. Although we do not think this is practicable, we understand the sentiment. As Solihull Care Trust suggested, “local authorities will struggle to co-ordinate commissioning without a commitment from partners to joint/pooled budgets”. However, we agree with Suffolk and Great Yarmouth LPC when they say that “integrated working depends on the quality of local working relationships and although the Department can outline areas where integrated working is required this should not be too restrictive to prevent local innovation to occur”. This is backed up by the Lesbian and Gay Foundation’s suggestion that “lead commissioning and other flexibilities should be explicitly promoted and supported by the Department for the delivery of high quality community based specialist services”. Staff at Norfolk PCT echoed the views of many NHS respondents when they welcomed “the opportunity to increase dialogue between services and join services together for the good of patients”. The Bill will therefore place a duty on GP consortia and local authorities, through the health and wellbeing board, in drawing up the joint strategy, to consider how to make best use of the flexibilities they have at their disposal, such as pooled budgets. To reinforce this duty, the Department has also decided that the NHS Commissioning Board should be placed under a duty to promote the use of flexibilities by consortia. These duties do not require flexibilities to be used, but they signal the importance of maximising the use of the tools available.
"In the reformed system, the process and product of the joint strategic needs assessment takes on much greater importance. The health and wellbeing board will have a role in helping meet the need - expressed by the NHS Confederation and others - for GP consortia to have “access to public health expertise so that they can take a population health viewpoint, in particular access to epidemiological advice and insight into parts of the population that are either unregistered or invisible to general practice”, through for example the Director of Public Health being a member of the board. As Southampton City Council has suggested, the focus on the JSNA will help “ensure that GP consortia take commissioning decisions based on the overall needs of the population in future rather than the needs of their current set of patients”.
5.20 The Government fully agrees with the view of the Association of Directors of Adult Social Services that “all commissioning should be driven by the JSNA or shared assessments across local authority boundaries, whether these are GP commissioning, council commissioning or joint commissioning”. Many respondents, for example the Association of Directors of Public Health, Nottingham City Council, Oldham PCT, and Peterborough City Council, felt that the value of the JSNA could be enhanced by clearer expectations about its use within commissioning plans. The point is well made. At present JSNA obligations extend only to its production, not its application. To remedy this lacuna, the Government is therefore introducing in the Bill a new legal obligation on NHS and local authority commissioners to have regard to the JSNA in exercising their relevant commissioning functions.
Added to this was a commitment to strengthen the distinctive role of Scrutiny Committees, including the ability to scrutinise the decisions of GP Commissioners.
So we made some progress. And it's good to note that the Coalition actually listened to the responses and adjusted their approach accordingly.