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Consultation on a Strategic Commissioning Organisation for Staffordshire and Stoke-on-Trent Appendix: Correspondence

Monday, 2 September 2019

midlandsandlancashirecsu.nhs.uk Table of Contents 1 Tamworth Council ...... 3 2 Healthwatch Stoke-on-Trent ...... 4 3 North Staffordshire Combined Healthcare Trust ...... 7 4 Reach (part of Assist) ...... 9 5 Stoke-on-Trent City Council ...... 11 6 Adults and Neighbourhoods OS Committee, Stoke-on-Trent City Council ...... 13 7 MP ...... 15 8 Staffordshire Moorlands District Council ...... 16 9 Jeremy Lefroy MP ...... 17 10 University Hospitals North Midlands ...... 18 11 Staffordshire County Council ...... 19 12 Cannock Chase Council ...... 21 13 Healthy Staffordshire Select Committee ...... 25 14 Hednesford Town Council ...... 27 15 Newcastle-under-Lyme Borough Council ...... 28 16 Midlands Partnership NHS Foundation Trust ...... 29 17 Healthwatch Staffordshire ...... 30 18 Ruth Smeeth MP ...... 31 19 Gareth Snell MP ...... 32 20 Public correspondence ...... 33

2 | NHS Midlands & Lancashire Commissioning Support Unit 1 Tamworth Council Hi both- thanks for taking the time to meet with us yesterday and for offering to engage with elected members further with a training session and discussion.

Clearly, it was very helpful to further understand the nature and purpose of the consultations and engagements underway. I also met with Jennie Collier of MPFT this morning to discuss the plans for engagement in respect of the future of mental health service provision, particularly relating to the George Bryan Centre.

I just wanted to quickly feedback regarding the proposals for a single CCG as I have understood them-

Firstly, I welcome the commitment you articulated towards local devolution of decision making and the establishment of a local teams based on cross district geography which I think is very positive. As I explained in the meeting, for some time and for a number of reasons we have not achieved the same level of engagement with the CCG in our local partnerships as with some other partners. I would anticipate an increased level of involvement with the new locality manager and locality teams and I will be keen to develop the necessary links to further support our shared objectives. I think that the staffing, commissioning and accountability structure you describe helps to mitigate risks represented by further organisational centralisation. I hope this will promote a locally sensitive commissioning approach where appropriate.

Divisional Committees, meeting in public, will add a further opportunity for residents to engage with the CCG decision making process along with your arrangements for patient engagement.

We discussed the decision not to hold an event in Tamworth and you explained the rationale for this and referred to the wider consultation- Together We’re Better- which clearly will be of greatest interest for most residents.

As far as other matters relating to the proposed changes- clearly I am not in a position to comment and I would assume that scrutiny of maters such a costs savings, impact on the Health economy, effectiveness of governance and compliance are matters which will be subject to scrutiny/consideration from NHS England, the HWBB and Overview and Scrutiny at a county level rather than for comment by Districts. We did discuss the need for proposals to be discussed at the regular Staffordshire CE meetings if this has not already been undertaken.

I will look to make contact with Nicki Harkness to discuss further engagement in partnership structures.

If you need anything further please let me know.

Kind Regards

Rob Barnes Executive Director Communities

3 | NHS Midlands & Lancashire Commissioning Support Unit 2 Healthwatch Stoke-on-Trent

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6 | NHS Midlands & Lancashire Commissioning Support Unit 3 North Staffordshire Combined Healthcare Trust

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8 | NHS Midlands & Lancashire Commissioning Support Unit 4 Reach (part of Assist) Reach Feedback – Single CCG Consultation (June 2019)

Who We Are Reach is a group advocacy project supporting people in Stoke-on-Trent to speak up about their lives and the issues that affect them. Reach is part of Asist, Advocacy Services in Staffordshire.

What We Did We agreed to work with adults with learning disabilities to look at, and comment on the public consultation on whether all six Staffordshire Clinical Commissioning Groups (CCGs) should join together as one organisation.

We looked at the information sent out by the CCGs, produced accessible ‘Easy Read’ posters based on the information and attended a meeting at the Medical Institute in Hartshill on Wednesday 22nd May to find out more about the proposals.

We invited people to a meeting at our offices in Winton House, Stoke-on-Trent where we facilitated the meeting, and made notes based on people’s ideas, comments and questions.

10 adults with learning disabilities came to the meeting. There were 5 men and 5 women, aged between 35 and 75. Everyone who came to the meeting lives in, and uses NHS services in Stoke- on-Trent.

What People Said All the main ideas, comments and questions from the meeting are detailed below.

People wanted to know how this would affect them personally. • “Will this make staffing and waiting times better at the hospital? There’s not enough doctors as it is now.” • “Will any of this actually make it better when I go to the GP?”

People were concerned that one Staffordshire CCG would be too big to respond to local health needs. • “How will just one CCG support the whole of Staffordshire? That’s a lot of people. A big area.” • “If there’s only one CCG, how will they make sure they’ve got the right information and money for everywhere in Staffordshire?”

During the discussion, we asked people if they felt that Stoke-on-Trent needs its own CCG. All 10 people said they thought the city’s health problems were different from the rest of the county. • “We’re better off having one for the city.” • “If we still have one just for Stoke-on-Trent, it’ll work better.” • “Because of all the poor areas we’ve got in Stoke-on-Trent. We’ve got lots of homeless, alcoholics, drug addicts that all need a lot of services and care.” • “That’s why you need more local help, from a local CCG.”

People were concerned about money and funding. • “Making big changes always costs more money than they think. It’ll end up costing more in the long run.” • “What happens when they switch over to one big CCG but then in a few years they don’t get the same money from the government?” • “How’s this all going to help with all the GP surgeries that are shutting down?”

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Some people wondered how widely known this consultation is. • “How will people be helped to understand all this, know what’s going on?” • “They [the CCGs] need to make sure patients have their say about everything.”

Some people said they didn’t care how the CCGs are organised, as long as NHS services are good. • “As long as they get the work done, and they run the NHS, that’s all I’m bothered about.” • “The main issue is making sure people get the care they need and that it’s good care.”

Contact Us Telephone: 01782 845584 Email: [email protected]

10 | NHS Midlands & Lancashire Commissioning Support Unit 5 Stoke-on-Trent City Council Dear Marcus

Thank you for inviting the City Council to comment on your application to NHS England to explore the opportunity to form a single statutory CCG for the whole geographic area of Staffordshire and Stoke-on- Trent, responsible for decision making and commissioning of services for a 1.1 million population. I understand that, following a wide consultation, a decision will be made by the CCGs’ GP Members in September 2019 whether or not a formal application should be made to NHS England.

I am replying as Deputy Leader of the City Council and Lead Member for Health and Social Care to register our concerns about the proposal and our strong objection to any such merger being made. As a major stakeholder, I would expect our view to be given appropriate weight and consideration.

Stoke-on-Trent is the 14th most deprived local authority in the country with significant health inequalities, a dense urban nature and very different demographically and geographically from Staffordshire with high need and a population carrying a significant burden of ill health. This has always been recognised by an above equity Public Health Grant and additional deprivation element factored into the CCG allocations.

We are concerned that there would be a north to south shift of funding and there would be a loss of transparency about exactly where the funding intended for Stoke-on-Trent residents would be spent. We are aware of the acute financial pressures facing the NHS and have no confidence that promises to maintain local funding levels would be kept and that funding would be flexed as part of the new “Intelligent Pricing System” which is essentially a risk sharing mechanism.

We have enjoyed a shared geographic focus with the CCG, and the PCT before that, which has enabled us to work closely together to address the very specific needs of our population through good partnership working and the governance of our City Health and Wellbeing Board. We are able to work swiftly and jointly to tackle issues as they arise and work closely with our local NHS Providers.

We have seen the effect of some of the suffocating bureaucracy of the STP/ICS and believe that a single CCG will simple delay decision making and, more importantly, move it away from the local decision making. We are 25% of the population that would be served by the new CCG, and the most needy 25%, and yet we would become essentially one sixth of a new CCG that would have a focus on “out of county” matters and spreading services equally across City and County.

We are currently working closely with the local CCG, and its partnering North Staffordshire CCG, and other Stakeholders as part of the Northern Alliance and on Integrated Care Teams. We are jointly driving these agendas forwards and have made far more progress than colleagues in the other two Alliance areas. We have a well-defined “care system” with an excellent Acute Hospital that is accessed by 99% of our residents and our own MH and Community Trust within the City. We believe that an amalgamation of the two CCGs across Stoke-on-Trent and North Staffordshire could be made to work and we could support that as an alternative way of working.

In short, we believe that we would lose our local focus and decision making capability, we would see funding move from north to south and we would see a shift in emphasis away from population need to sorting financial pressures. As a result, we believe that the needs of our population would not be optimally met,

11 | NHS Midlands & Lancashire Commissioning Support Unit health outcomes would get worse and health inequalities would increase. We believe that working relationships would suffer and the Northern Alliance would lose momentum.

Therefore, I would like to register our formal objection to the proposal to form a single CCG for Staffordshire and Stoke-on-Trent and wish to either retain the status quo of a single CCG for the City or an amalgamated CCG across Stoke-on-Trent and North Staffordshire on the same geographic boundaries as the Northern Alliance.

Best wishes

Ann

12 | NHS Midlands & Lancashire Commissioning Support Unit 6 Adults and Neighbourhoods OS Committee, Stoke- on-Trent City Council

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14 | NHS Midlands & Lancashire Commissioning Support Unit 7 Paul Farrelly MP Dear Anna

I hope all’s well and thank you to your team for the reminder about this latest consultation.

I’ve only got some brief input, as follows:

As the MP for Newcastle-under-Lyme for the past 18 years, and with involvement in our local NHS for longer than that, I have been witness to all of the local health re-organisations from replacement of the old North Staffs Health Authority to mergers of the subsequent Primary Care Trusts and their replacement by Clinical Commissioning Groups, which are in turn now to merge.

My position throughout has been consistent in that I believe health services are more responsive to the needs of our local communities in North Staffordshire when they are organised and governed locally.

I, therefore, oppose the creation of this single CCG for the whole of Staffordshire and Stoke-on-Trent, which will inevitably be rooted in . The County is a very diverse area, with no natural connection between its various component localities, and Stafford often lies a million miles away in terms of its priorities.

I would also mention that this goal of a merger of all CCGs has been consistently denied, when that has obviously long been untrue, not least with the appointment of a single Accountable Officer for all six.

The body behind all this, NHS England, since its creation after 2010, is also – in my experience – the least accountable public sector organisation I have encountered in my time as an MP. So, all in all sadly, the problem of trust in the management of our NHS strongly endures.

All the best and grateful if you could feed this in

Paul

15 | NHS Midlands & Lancashire Commissioning Support Unit 8 Staffordshire Moorlands District Council Hello, Following the meeting of the Health Panel, at which the CCG set out its proposals for the Single Strategic Commissioning Organisation, I have set out the main points raised by members below. I would be grateful if you could make any amendments/ approve this by tomorrow prior to the closure of the consultation on 30th June 2019.

• That the CCGs recognise the difference in needs of patients and the providers of care for the North and South of the County; • As the Staffordshire Moorlands has a large rural population it has different needs to other parts of the County; • Members were very concerned that as the CCGs had different policies, there would be a levelling down of the services provided to patients to the lowest common denominator; • Members were not convinced that a single CCG organisation would improve the level of service provided and patient care. • It was highlighted that the main services the public wished to see improvements to were, GP appointments, Out of Hours and an increased number of nursing staff; • The proposed structural changes had been seen since the 1980s and it seemed that there was a constant churn of change for little practical result; • Members felt that the main driver for change was to reduce costs; • That there was no clear evidence to support changes to social policies; • Some members thought that GPs should be able to influence decision making without a merger of the CCGS; • That localism would be lost if the CCGs were to merge into one organisation; • Some members agreed with reduced management within the proposed new structure but voiced concerns in relation to how this would fit in with other organisational structures and the voluntary sector; • That feedback should be gathered more regularly and from a wider group of people; • It was suggested that there should be a method to measure the impact of the proposed changes. Best regards,

16 | NHS Midlands & Lancashire Commissioning Support Unit 9 Jeremy Lefroy MP Dear Sir or Madam

Regarding the consultation about the proposal to develop a new, single CCG out of six CCG’s, Jeremy Lefroy, the Member of Parliament for Stafford, would like consideration to be given to the question of funding. The current CCG’s receive different levels of funding, reflecting the parts of the county they represent. How would this be managed if there was one CCG in future?

Kind regards

17 | NHS Midlands & Lancashire Commissioning Support Unit 10 University Hospitals North Midlands

18 | NHS Midlands & Lancashire Commissioning Support Unit 11 Staffordshire County Council

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20 | NHS Midlands & Lancashire Commissioning Support Unit 12 Cannock Chase Council

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24 | NHS Midlands & Lancashire Commissioning Support Unit 13 Healthy Staffordshire Select Committee Hello At the Healthy Staffordshire Select Committee held on 15 July 2019, the Committee considered the report on the proposed creation of one CCG. The Committee e past the following resolution

RESOLVED: That the Committees concerns, as listed below be fed into the consultation: a. There was concern that the move was financially led and that commissioning policies hadn’t been mentioned. The Committee were concerned that the North and South had a very different population need and local need should be recognised. There was a concern that commissioning policies would be changed to the detriment of the public. b. It was felt that cultural change was needed more than changing the structures.

Could you please include these comments in the consultation feedback

Staffordshire County Council County Buildings Martin Street, Stafford, ST16 2LH Telephone: (01785) 278502 Email: [email protected] Web: www.staffordshire.gov.uk

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26 | NHS Midlands & Lancashire Commissioning Support Unit 14 Hednesford Town Council Dear Sir/Madam

Further to my email of 30 July I should be grateful if you would revise the Council’s observations to read as follows:

The grounds for our objection to the proposed merger is our belief that governance structures of CCGs should remain autonomous and local to their represented communities. Our community has first-hand knowledge and understanding of its local health needs; the CCG needs to remain at local level in order to stay in touch with those needs.

27 | NHS Midlands & Lancashire Commissioning Support Unit 15 Newcastle-under-Lyme Borough Council From: Wright, Ruth (Cllr) Sent: 20 August 2019 15:22 Subject: Re: [UNCLASSIFIED] Single Strategic Commissioning Organisation

Hi I support keeping the present arrangement of 6 separate CCGs if you would let them know. Many thanks

Kind Regards,

Cllr Ruth

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17 Healthwatch Staffordshire

Feedback from Heatlhwatch Staffordshire to consultation on proposals to create a Single Strategic Commissioning Organisation across Staffordshire.

From the feedback we have received on this issue the overall conclusion is that there is broad support for the proposals as a way of bringing fairer more consistent services for patients across the county. Also there may be economies of scale and savings to be made from reducing the number of commissioning bodies which could be reinvested into services. There were however a few points in particular for the CCG to consider and address in respect of the proposals

1. How can ensure that they remain sensitive to local needs? Staffordshire has areas of great deprivation in areas of Cannock and Stoke whose needs we’ll may be different to more affluent areas of the county. 2. How can they ensure people still have an effective voice? If Governing Body meetings are centralised then there will be transport issues for the less mobile, if they rotate through various venues then continuity will suffer. Could there be public PPG meetings in the original CCG localities? 3. It’s a good thing to create some consistency across Staffordshire and stop the postcode lottery in terms of access to services, however will the CCG work to the lowest common denominator in order to cut services across the board. E.g. Provision of Hearing Aids to hearing impaired people currently denied to people who live in North Staffordshire . will individual decisions of this nature just be rolled out across the county without any proper analysis on the impact or debate on these issues?

4. Will areas of higher depravation like Stoke will end up with a disproportionately higher cut of the money and resources because of the depravation of the area and therefore more affluent areas will lose out . example given which is not CCG but could still be applied similarly is Heath Checks that are no longer available in certain ‘ affluent’ areas of the county but are in other areas considered more deprived. This is seen as discriminatory. Would commissioning decisions be similarly arrived at from a single commissioning CCG body?

Hope this is useful feedback to be taken into account Kind regards

Jackie Owen

30 | NHS Midlands & Lancashire Commissioning Support Unit 18 Ruth Smeeth MP

31 | NHS Midlands & Lancashire Commissioning Support Unit 19 Gareth Snell MP From: SNELL, Gareth Sent: 23 August 2019 17:33 Subject: SSCO Consultation Response

RE: SSCO Consultation Following a consideration of the documents provided publicly and the presentation I attended earlier this year, I wanted to write and formally record my objectives to any merger of the Clinical Commissioning Groups in Staffordshire. My general opposition to such a merger is that while Marcus Warnes remains the accountable officer for all six CCGs, I do not believe any governance changes which would allow him to fortify his own empire and hide his woeful inadequacies would be in the public interest. Sadly, the response from the six CCG chairs in Staffordshire which sought to play down the severity of in the inadequate ratings recently achieved by the CCGs has left me with little confidence that any significant change would be well managed or, indeed, improve the operational or financial standing of the organisations. To dismiss the fact that half of all inadequate CCGs in the Country are in Staffordshire and to seek to merely declare this as nothing more than a national problem suggests to me that the strategic priorities of the CCGs ought to be fixing the local messes rather than seek governance and structural change and certainly while the clinical chairs proclaim their faith in Marcus, I would not support any changes in the governance arrangements that could allow for less accountability of the accountable officer. I also have not been convinced by the arguments progressed that there is anyway of ringfencing and protecting the relatively higher per capita allocations for Stoke-on-Trent and North Staffordshire within a single CCG and this would, in my opinion, lead to a reduction in per capita funding for the CCGs in Stoke- on-Trent and North Staffordshire. This worries me greatly as the CCGs determination to cut budgets on community provision and their previous wilful desire to punish UHNM through fines has given the reputation of being more concerned about trying (and subsequently failing) to balance its own budgets at the expense of provision for my constituents. Reducing the per capita allocation to a county wide average would, I believe, lead to further cuts to the services my constituents depend on while those parts of the county that are already funded to a lower level than Stoke-on-Trent and North Staffordshire would likely be less effected. I also have concerns about moves towards countywide commissioning for services. The CCG already struggles to maintain a good relationship with the local voluntary and third sector groups. Moving to larger and more generic county wide contracts for certain services would disadvantage my constituents who have specific and different needs. It would also mean fewer community, third sector and community groups would be able to bid for contracts and there would be a convergence of service delivery either in national infrastructure organisations or in one of two existing providers, reducing innovation and localism. Finally, until the responsibilities of the STPs are codified and the system in sure who has actual responsibilities as you inevitably move towards an ICO, I am not supportive of any meger of CCGs.

With kind regards

Gareth Snell

Gareth Snell MP

32 | NHS Midlands & Lancashire Commissioning Support Unit 20 Public correspondence Please can you include Biddulph in your list of venues for the consultation meetings. Once again we are left out and the venues listed are difficult for Biddulph residents. Please give us a chance to be included in this and any further meetings you decide to arrange. Thank you for reading this email request, Good evening,

As a member of a PPG based in Tamworth, I am extremely concerned to see that there is no planned meeting taking place in Tamworth, where there is a large and expanding population, as we are in the process of having 5,000plus new homes built, with an estimated rise in the population of 15,000 people. We are asked to share the information regarding meetings with patients, the public. community and voluntary groups, health and care providers and local authorities. Our nearest point to attend a meeting is Lichfield... there is little public transport between Lichfield and Tamworth and it cannot be assumed that all interested parties have their own transport.Perhaps further consideration should be given to a meeting being held in Tamworth. Hi,

Comments on the proposal to create a single CCG for Staffordshire

I started to complete the questionnaire on the structure of the CCGs for Staffordshire, but it was asking questions which are not pertinent to the decision. Therefore I wrote the following.

I do not believe that the general public have any particular view on the structure of the NHS. What is important is the care that is deliverable through whatever structure is believed to be necessary. There are some aspects that ought to be considered irrespective of what the ‘business’ structure emerges: • In industry and commerce, decisions are rarely made by committees but by individuals who take complete responsibility for them. This does not seem to be the case in the NHS where ‘managers’ spend most of their working lives in meetings. • Consultation, whilst useful if directed appropriately, ought to be with those individuals and groups who will be significantly affected by outcome. To have public consultation on internal structures at the level of CCG is a step too far and unnecessary. • Certainly get the views of those professionals external to the NHS who have managed large organisations but the vast majority of the public have never played such a role and their opinions are not based on experience. • Don’t spend NHS money and time on spurious consultations – get on and, with those directly involved and/or affected, identify the real options and their pros and cons and make the decision. • Whatever structure is decided upon, make sure that it implements the structures necessary for TWB and provides us with an effective caring NHS.

All the best, I am aware there are obvious differences in funding and financial positions of the CCG’s and how they fund primary care This is divisive and is a postcode lottery for patients as well as GP’s and the services they are trying to provide. I suspect a combined CCG will have all the issues of balancing the budgets and funding one position from another.

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I am under no illusion that the CCG, whilst attempting to be a membership organisation, has to do what its told. I have come across these governmental consultation periods. It is a matter of members agreeing, we have no power.

Consequently I wish this was made plain and not waste too much time. CCG’s cant work with a shrinking workforce so they need to combine. I suspect it is inevitable and we just all need to such it up and get used to the new world

Further to our telephone conversation, I am not against a single CCG, but experience the frustrations listed below. This is a copy of an email sent to my own GP Practice and the leader of our local PPG.

I have been struggling to send feedback about the proposals for a County Single CCG to the supposed feedback offices/telephone number listed in the documentation surrounding this one horse proposal.

This morning (Monday) it appears that the deadline has been extended for feedback comment until June 30th. I have been given a contact name at the CCG - Julie Naylor tel. 01782 872 704.

My own response to the proposal is as follows:

The documented proposal that I have received regarding the proposed single CCG for the County is superficial, contains statements about economic savings that are unsubstantiated , has ambiguous phraseology, fails to acknowledge that Patient satisfaction also depends on the quality of care offered by commissioned providers, fails to recognise that a Patient referred to a third sector (i.e. non-clinical provider) then moves from being a Patient to becoming a Client. As such, Patients have no guarantees about external record keeping and confidentiality, the Service Provider may have no direct contact with the referring GP and be unaware of the Client's medication levels which may impact on treatment outcomes. If the Service Provider is a Charity then the Client may, without the referring GP knowing, be invited to make a donation to that Charity. The Patient, originally treated free of charge by the NHS, then effectively becomes Fee-Paying.

I have observed this to be the case after working in the NHS in the field of emotional and mental health and subsequently working voluntarily in charities dealing with relationship conflict.

The documentation boasts of economic savings to be made (without detailing how) but says nothing about the costs of drafting, distributing, assessing the outcomes of this supposed feedback exercise which has already met with deadline changes and with problems in respondents accessing anyone at the CCG who might speak with informed authority. The greater emphasis appears to have been on political correctness in classifying personal data pertaining to the person giving the feedback.

Kind Regards,

HI,

I am sorry that this is being done at the last moment but I have had a hard job making my decision and decided to leave it until the final day fully expecting the online consultation to end at the end of

34 | NHS Midlands & Lancashire Commissioning Support Unit the day not earlier. I suspect that the second option will be adopted as that is the way that the people involved in the CCGs appear to be leaning.

Option One - Keep the current arrangements of six separate CCGs under a single leadership team I feel that this arrangement lends decision making to be more local. A local CCG understands their area rather more than a single CCG would.

The obvious disadvantage is 6 sets of accounts, AGMs, etc.

Option Two - Develop a new single CCG The advantages are one set of work - see above and an overall view of the county which may improve the pathway for the patient and allow specialist work to be set up.

I cannot help but worry that some areas will be treated more favourably than others. The general perception even now is that Stoke gets "better resources" than other areas. I fear this might increase under one single CCG.

If you still have local boards reporting upwards to one CCG won't that be similar to now but will divest the local groups of any power they have to direct resources?

General thoughts: I wonder if we just keep on changing things for change's sake rather than looking to improve healthcare? I have not been involved as long as some of my colleagues but there seems to be a certain feeling of "here we go again". There must be a financial implication on this constant change plus a possible demoralisation of staff.

Having thought whilst typing I think I am marginally in favour of keeping things as they are i.e. 6 CCGs. I allow this my response to the above to be used as such and wave all rights to this my response being confidential.

1. I am seriously concerned and diametrically opposed to a single overarching NHS Commissioning Body for the entirety of Staffordshire. 1. 2. The proposals seems far more concerned about the “needs” of an organisation namely the proposed SCO than truly bearing down on the real and disparate needs of local populations within Staffordshire. In fact it would seem to be a somewhat spurious tactic to give a non statutory body ..namely the Staffordshire STP the “legal” authority that at present reside in the INDIVIDUAL CCGs 2.

35 | NHS Midlands & Lancashire Commissioning Support Unit 3. CCGs have statutory duties and responsibilities to be both accountable to and improve the health and well being of their catchment populations. As they have EXTENSIVE local knowledge they can and do identify granularity of health indices of their populations and as Commissioners they are required to performance manage any and all services Commissioned (using PUBLIC monies) ensure that they do carry out their statutory requirements, ensure compliance to national priorities and clinical requirements eg NICE requirements and report such in publicly available decipherable papers. These requirements have been in place via differing Government policies throughout this century and applied to predecessors of the CCGs (PCTs and Local Health Authorities)

4. A portend of things to come has been that over the last year or so the CCGs moved to in effect one Executive Body throughout Staffordshire. Result of such is a return to what I term the “bad old days” of the NHS..an increase of policy documentation and a significant decrease of any and all forms of Performance Management. At this moment Performance Reporting (which includes quality and safety) is the worst I have seen since the days of emerging PCGs in the early 2000s.

5. An overarching Staffordshire wide CCG will likely NOT bear down on granularity of services and will lin fact likely (as at present) aggregate performance/cursory analyse specified discrepancies. 3.

6. In his letter of 9th May Mr Warnes extols the supposed advantages..simpler decision making..region as a whole financing....and a vague..”we expect patient experience to impove..joined up services etc ‘better’ access etc etc. I fail to understand how in effect centralising Commissioning into a Staffordshire wide CCG will honestly openly transparently and accountably truly address the needs of for example the needs of the population of Stoke-on-Trent. As is well known the MAGNITUDE of deprivation within Stoke-on-Trent far exceeds anything anywhere near comparable elsewhere within the County of Staffordshire. I would also point out the significant health inequalities in Staffs. Moorlands and of course within Newcastle under Lyme.

7. A Staffordshire wide Commissioning Organisation would dilute accountability to the differing sub regions of Staffordshire and most certainly DILUTE the voice and perceived “ownership” within those sub regions. It most certainly will dilute the “voice” of Stoke CC OSC as Stokes population is only approximately ¼ of te entire population of Staffordshire yet Stokes proportional needs are significantly higher. StokeCC voice would be weakened. 4.

8. I would most certainly advocate something approaching the lines of what was the old North Staffs Health Authority and for the South Staffordshire something akin to the South Staffs HA.

9. We in Northern Staffordshire have a well defined Northern Staffordshire “CARE System” ..not perfect granted but a system that has been increasingly responsive to local significant need. We have situated in the patch THE major tertiary Acute Unit namely Royal Stoke and of course a major Acute MH hospital Harplands and a successful MH Trust Combined HealthCare. Relations with Stoke CC although having been strained somewhat have dramatically improved. I cannot for thelife of me

36 | NHS Midlands & Lancashire Commissioning Support Unit understand why that improvement moment should have to now cope with an ill thought through proposal to create a single overarching Strategic Commissioning Body. 5.

10. If NHS/Care Commissioning is to be taken seriously the propsed Divisions should NOT be subordinate to the SCO. The SCO should in fact be a sub committee of the proposed Divisions. Any SCO decisions would then be ratified or Challenged by those with local duties and responsibilities to their populations. Otherwise SCO will be tempted to IMPOSE decisions on local Divisions and thus local populations. Such although to quote Mr Warnes “simplifying decision making” are most certainly NOT in populations interests.

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