Trust leaders agree that regulatory models need to adapt to the evolving health and care landscape, with a particular need for regulation and oversight to take into account the wider system context. CQC and NHS England and NHS Improvement have set out promising new frameworks designed to build a picture of quality and performance across systems, as well as provide an enabling framework for trusts to collaborate with partners. Despite the positive direction of travel, there are clear unanswered questions about how these new models will negotiate existing accountabilities, ensure that intervention is made at the right level, and that ICS level assessments meaningfully add to what already exists.

Over the coming months, the regulators will be developing and refreshing their approach in anticipation of new legislation from April 2022. NHS England and NHS Improvement will be updating the System Oversight Framework for 2022/23 and CQC continues the development of frameworks for reviewing ICSs. This briefing has highlighted some of these questions and risks and detailed a set of principles for a good future regulatory system. As the regulators look to embed their new models, and trusts continue to work through the implications of new legislation on their accountabilities and the role of ICSs, we will look forward to working together to ensure these complexities are addressed.