- The results of this year’s survey reflect the fact that the sector is in a period of transition as new regulatory and oversight frameworks are developed which support system working, and as NHS England and NHS Improvement align their activities.
- Trust leaders are optimistic that the new national structure will be more efficient and better placed to support system leadership through providing a more joined up perspective. However, the findings indicate that, under the new joint working arrangements with NHS Improvement, there will be a need for NHS England to rapidly develop and demonstrate its understanding of the provider sector. Trust leaders also see opportunity for the national NHS leadership to use this juncture to reset the culture towards one of improvement support and to focus on shared culture, values and behaviours.
- It is encouraging that most trusts reported a sense of stability in the level of regulatory burden over the last 12 months. This is in contrast to each of the previous four years in which we have run this annual survey when the majority of trusts have said that the burden had increased. There has also been an improvement in the proportion of trusts who agree that reporting requirements are proportionate to the level of risk they manage.
- However, trust leaders' experiences of the regulatory framework reflect a mixed picture. While there are promising indications of improvement in some areas, in other respects providers’ experiences have worsened over the last year. This year, fewer respondents said that the overall regulatory framework of the NHS is working well than in previous years, and there has been no increase in the proportion of trusts who believe the regulatory framework offers value for money.
- Trusts continue to feel the tension between the current institutionally-focused regulatory model and policy ambitions to develop methods of oversight for local systems. They feel that the move to greater system working and system-level oversight risks blurring existing lines of accountability and placing additional regulatory burden on providers.
- Nonetheless, trust leaders are optimistic that it is possible to develop new models of oversight to hold systems to account for the collective performance of their component organisations. However, respondents also pointed out that without legislative change, systems will remain fundamentally voluntary arrangements and questions will persist as to how whole systems can be held accountable.
- Trusts continue to tell us that NHS Improvement’s approach is generally one of performance management rather than of support, despite the national focus on becoming an improvement support agency
- Trusts that took part in Care Quality Commission (CQC) local system reviews found them valuable. However, trusts’ hopes for CQC's revised regulatory approach for organisations have not yet been realised.