Authorisation, oversight and the failure regime

The IHO authorisation or award process, like that for new FT authorisation, must be robust. The plan does not specify if an IHO is a new legal form of organisation, and whether IHOs will be overseen by the same independent panel as for new FT authorisation. 

Ongoing oversight by the regions 'in a rules-based way' is proposed in the plan, and we assume IHOs would be subject to the same regulatory regime as other new FTs. There is potential for a distinct approach within the existing regulatory framework, as is currently being taken with ICBs and providers both being assessed via the NOF. As they are closely associated with new FTs, IHOs will presumably remain under the provider licence. 

The failure regime for IHOs as organisations, or for any organisation commissioned as an IHO, should be thought through: it is potentially more complex in terms of delegated commissioning functions across primary and secondary care, for example. As with new FTs, consideration should be given as to whether there will need to be a deauthorisation process or contract transferral process for IHOs which experience major performance or financial issues, or which fail against other criteria. When a local health system is designed around a provider, it is not a simple matter to move to a different arrangement if things go wrong.