It has been recognised for a long time that being able to deliver integrated care is a key element of an effective health service. There have though been a number of significant barriers preventing this from happening. Monitor has therefore published a consultation regarding how health and well being boards and healthcare providers can meet their integrated care obligations.
What is integrated care?
Monitor’s view is that integrated care is:
- primarily about individuals’ experience of care and ensuring better outcomes through co-ordinated, person-centred care and support; and
- integrated care is neither necessarily about structures, organisations and pathways, nor about the way that care is funded or commissioned.
Integration in Monitor’s view may also refer to how services are configured to deliver seamless care, where the patient or user perspective is the organising principle of service delivery.
Who do the requirements apply to?
There is a requirement regarding integrated care within Monitor’s new provider licence. This means that all licence holders will be required to comply with the integrated care requirement and not do anything that could reasonably be regarded as detrimental to enabling integrated care. There is though only a requirement to comply with this obligation to the extent that it is in the interest of patients. Monitor is currently consulting on draft guidance associated with the integrated care licence condition (https://www.gov.uk/givernment/consultations/integrated-care-licence-condition-draft-guidance-for-providers-of-nhs-funded-services).
Although NHS Trusts are not required to hold a provider licence they are required by the NHS Trust Development Authority to comply with an equivalent condition in relation to integrated care.
What sanctions apply where there is a failure to comply?
If a licensed provider fails to comply with the integrated care requirement Monitor will take enforcement action. This may include Monitor formally investigating breaches and imposing additional requirements on the licensed provider should a breach be found. Details regarding the enforcement process can be found at https://www.giv.uk/government/publications/monitors-enforcement-guidance.
If a NHS Trust is in breach of its integrated care obligations Monitor will inform the NHS Trust Development Authority and may also open an investigation. Should it be determined that a NHS Trust is in breach Monitor will inform the NHS Trust Development Authority regarding the breach and any recommended actions. The NHS Trust Development Authority will also notify Monitor is it believes a NHS Trust is in breach of its integrated healthcare obligations.
Is there a tension between the requirement to integrate and competition?
Monitor does not believe that these are mutually exclusive. It does though note that the extent to which different models of delivering care are likely to deliver better integrated care and their impact on competition and choice will need to be considered by the commissioner on a case-by-case basis. Note that it will not be regarded as anti-competitive behaviour if the commissioner’s actions are in the best interest of patients. Making this assessment will clearly not be straightforward and involve detailed consideration from a procurement, competition and clinical perspective.