NHSI consultation on updates to the Single Oversight Framework: NHS Providers response
NHS Providers submitted a response to NHS Improvement's (NHSI) consultation on proposed updates to the Single Oversight Framework (SOF). This included proposals to update the SOF metrics and indicators that trigger consideration of potential support, as well as changes to the presentation of the SOF document itself.
Our response included the following key messages:
- We support NHSI's iterative approach to developing the SOF and its engagement with NHS Providers in doing so. A commitment to improving and developing the SOF is important as it will give flexibility to the framework in a continuously changing external environment and will help ensure it is fit for purpose.
- However, operating a flexible and iterative framework will come with its own complexities. Firstly, the SOF will need to be fully developed and confirmed as far as possible at some point, to ensure that constant revisions or updates don’t impede providers’ ability to understand and meet regulatory demands. Secondly, an iterative process to developing a regulatory framework may make it difficult to asses the combined and cumulative impact of changes to the nature of the framework itself and the regulatory burden it places on providers.
- In addition to this, given the current direction of travel of Sustainability and Transformation Partnerships (STPs) and Accountable Care Systems (ACSs), NHSI will need to continue to work closely with providers and other national bodies to ensure the new framework develops alongside STPs and ACSs, as well as the development of new models of care, and the emerging organisational structures needed to support these new approaches.
- We welcome the changes to improve the structure, format and presentation of the SOF document which is now clearer and easier to read. Our members would still benefit from further clarity and detail around NHSI’s support offer and the decision-making process around segmentation.
- Our members would welcome further clarity on how specific metrics, such as the adult mental health out of area placements, will be applied.
- We recognise that NHSI should tailor support according to local needs, but NHSI should also ensure it adopts a consistent approach to operating the SOF across the provider sector.
- NHSI should base its oversight, using the SOF and underlying metrics, on the conditions of the NHS provider licence and provide more clarity on how the metrics included in the SOF align with the provider licence conditions.
- There is still a need for greater alignment of the special measures regimes with the SOF, as well as the STP ratings and CQC ratings.