We welcome the publication of NHS England and Improvement’s (NHSE/I) consultation on its new System Oversight Framework for 2021/22. Trusts are clear that there is need for greater alignment of oversight arrangements with the development of system working and are keen to engage with NHSE/I colleagues to constructively shape the practical implementation of these proposals now and over the coming year. Our response has been informed by engagement with NHS trusts and foundation trusts in England, including two roundtables attended by NHSE/I. We also include findings from our recently published regulation survey report, Reconsidering the approach to regulation, where relevant.

• This is an important opportunity to design a framework which enables success, supports collaboration, and provides oversight and assurance on indicators for population health, patient experience and quality of care.
• Trusts continue to face operational pressures related to COVID-19 as they tackle the care backlog and support their workforce to recover. We therefore welcome NHSE/I’s commitment to a phased and flexible approach to implementing the new framework. This is particularly important in the context of proposed legislative changes and the future statutory role of Integrated Care Systems (ICSs).
• Trust leaders welcome NHSE/I’s focus on aligning the oversight framework with the development of system working, but note that the framework reflects a significant move from ICSs being a forum for collaboration and planning, to a performance manager offering a new tier of oversight. This will considerably alter the relationship between ICS leaders and the component organisations within a local system. Some system partners will welcome this step and see it as offering a pathway to greater autonomy and greater collaboration. Others will need to strengthen relationships and build capability and capacity at the ICS level before being ready to lead effectively on system wide assurance.
• Trusts remain keen to ensure the framework complements their accountabilities, which will change under the proposed health and care bill. Greater clarity is required to reassure trust leaders on this point.
• We welcome the inclusion of health inequalities as part of the assessment of trusts' and ICSs' performance in support of concerted action in the wake of the COVID-19 pandemic. Trusts are keen to understand how their contribution to these metrics will be captured as part of wider initiatives involving many partners.
• We welcome the clarity provided by the segmentation approach about expectations and levels of support. This should be supported by a clear pathway for trusts and ICSs towards achieving higher segmentation. We would welcome clarity on how quantitative metrics will be balanced against more subjective measures such as leadership and culture.
• We are supportive of a system wide approach to quality, which must be supported by a robust definition and assessment framework, including how aggregation of organisation-level outcomes will be used to assess ICS leaders' contribution to quality, and how softer cultural and behavioural issues will be identified, assessed and discussed. The system-wide approach to improvement is also very welcome, alongside further detail on how wider system partners will support improvement under the recovery support programme.