We welcome the opportunity to submit evidence to the review led by the Rt Hon Patricia Hewitt to consider how the oversight and governance of ICSs can best enable them to succeed.

The key messages from our submission are as follows:

• Trusts support the focus of the review, however given the extent of the challenges they currently face, it should first seek to clarify and consolidate the existing statutory context, rather than reopening debate about how the NHS is structured.
• Trusts drive delivery partnerships/collaboratives within ICSs. National bodies must be comfortable with subsidiarity shaping delivery, with local partners best placed to identify local population-health priorities.
• Trusts favour fewer national targets focused on outcomes, coordinated and aligned across priorities in underpinning policy/guidance. Alongside the understandable focus on UEC and elective recovery, this must protect progress to prioritise mental health and community health services nationally and locally.
• ICBs and their place-based partnerships/provider collaboratives should agree shared outcomes locally between partners and have space to drive forward longer-term cross-system objectives.
• The national oversight and performance management framework needs alignment between the CQC, NHSE and ICBs without duplication. It should be streamlined and enable useful collaboration and clarity about accountabilities. Regulators’ behaviours need to match their stated intention: promoting autonomy while providing support.
• A better balance between national and local priorities, and a focus on outcomes, could streamline the data collection required by the centre. This is appealing to trust leaders who often report concerns about the burden/duplication created by national, regional and system data reporting requirements.
• National investment and support is required to implement electronic patient records, which are essential to providing safe joined up care. This will enable accurate real-time data that can support clinical decision-making across the system.  
• System governance and organisational forms should be as simple as possible to enable control of safe, effective activity. NHSE and government should resist attempts to define what effective partnership-working/collaboration looks like in terms of inputs/structures, and focus on outcomes.
• Policy and guidance should respect the roles of statutory organisations (including trust boards) and their legal accountabilities.

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