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The NHS Long Term Plan and ICSs: to regulate or not to regulate?

Friday 4th October 2019

Olha Hodgson, Consultant
NECS Yorkshire and Humber Consultancy Team

Olha Hodgson, Consultant at NECS, discusses the role of Integrated Care Systems in the delivery of the NHS Long Term Plan, and whether these systems require a statutory regulatory framework to ensure consistency of commitment in the current unstable political climate.

In early September 2019, I attended NHS Expo, the UK’s largest annual healthcare convention.  This year’s Expo was the first one following the announcement of the NHS Long Term Plan (LTP) in January 2019.  It also coincided with the Brexit-driven political crisis which, not surprisingly, was reflected in many discussions at the gathering.  Nevertheless, LTP was discussed extensively in numerous sessions, one of the key topics being the role of Integrated Care Systems in its delivery.

ICSs are central to the delivery of the LTP.  These are close collaboration initiatives between the NHS, local authorities and the third sector which are being developed with the aim to of delivering more seamless, integrated care for patients.  Currently 14 areas (Figure 1)1 across the country are actively working towards developing integrated care provision with the plan for ICSs to cover the whole country by April 2021.  Yet, despite their crucial importance, these systems are in the form of alliance partnerships without a legislative background.  In theory, participation in ICSs is entirely voluntary and any organisation can join or leave at any time4.

Figure1. Integrated Care Systems in England in September 2019 Source: NHS England (2019)

The fact that ICSs have no statutory basis is a natural transition from the more structured approach of their predecessors, the Sustainability and Transformation Partnerships (STPs) 1. Prior to 2017, when the first ICSs emerged, there were 44 STPs established to bring together key health and social care stakeholders for the purpose of developing local healthcare plans. In contrast, ICSs are primarily concerned with active integration and delivery. There is a reasonable argument that too much “red tape” can slow down these processes and hinder creative transformation. On the contrary, there is a concern that lack of regulation may result in regional variability in the integration efforts and widen the healthcare inequalities that already exist.

The LTP does consider the issue of ICS regulation. According to section 7.13 “…legislative change would support more rapid progress” in the delivery of the plan, and section 1.55 hints at the development of the “new ICS accountability and performance framework”, which will include the “integration index” metric3. While these are still to be achieved, NHSE/I continue to invest extensively in the development of the three major buildings blocks for integrated care: Personalised Care, Primary Care Networks and Population Health Management. To supplement these efforts, NECS has been supporting NHSE/I in the development of an ICS Maturity matrix on line self-assessment tool which can provide much needed baselining and points of reference in the ICS developmental journey.

Integrated Care Systems will be vital for implementing new models of healthcare and are the absolute cornerstone of the Long Term Plan. However, systems are in their infancy and there  is a debate to be had whether a dedicated statutory framework  could future-proof the ICSs against unforeseen political and economic developments and ensure ongoing sustainability.

Contact NECS Consultancy to understand how we have supported clients to think differently and develop new models of care. Find out more here: [Comms insert hyperlink to NECS Consultancy website]


  1. BMA (2019), Integrated Care Systems (ICSs). [accessed 20th Sep 2019] , available at
  2. NHS England (2019), Integrated care systems, [accessed 20th Sep 2019] , available at
  3. NHS England (2019), The NHS Long Term Plan, [accessed 20th Sep 2019] , available at
  4. The Kings Fund (2018), A year of integrated care systems: reflections on progress and next steps, [accessed 20th Sep 2019], available at
  5. The Kings Fund (2019), The NHS long-term plan explained. [accessed 20th Sep 2019] , available at