Response to the Government’s proposed reform of the NHS

The government suggested reform of the NHS could only improve services for people with mental health problems and learning disabilities if the proposed arrangements around closer joint planning and commissioning of integrated care pathways and services are strongly implemented.

GP consortia and the NHS Commissioning Board must consult and take account of specialist mental health, dementia, learning disability and social care expertise when commissioning services.

The Bill must also impose duties of joint planning and commissioning between GP consortia and the NHS Commissioning Board. Other health specialists and local partners, such as social care, housing and education agencies, must be involved by GP consortia in their commissioning decisions; and local Health and Wellbeing Boards must ensure similar representation to guarantee a holistic approach to health and social care.

HealthWatch must represent a full spectrum of patients, including people with mental health problems and people with learning disabilities; and must have a formal right to be involved in decisions about planning and commissioning services within Health and Wellbeing Boards and GP consortia and the NHS Commissioning Board.

The commissioning split between local GP consortia and the NHS Commissioning Board could potentially be disastrous. Exceptionally close working between local GP consortia and the NHS Commissioning Board is required, which doesn’t seem to be guaranteed under the present scope of the Health and Social Care Bill.

Our concerns are heightened by the lack of clarity that currently exists about precisely what services the NHS Commissioning Board will take on. If, for example, the Board was to commission psychiatric in-patient care across the country (including for people detained compulsorily under the Mental Health Act), while GP consortia commissioned crisis intervention services, it is very difficult to see how a smooth pathway of care could be achieved without close joint planning and commissioning.

Whatever its responsibilities, the NHS Commissioning Board will need to have access to specialist mental health and social care expertise for the mental health services that it commissions.