At the end of September, NHS England wrote to CCGs and area teams setting out in its “Proposed next steps towards primary care co-commissioning: an overview” slides its proposed three main models of co-commissioning, guidance and a timetable for implementation.
The three main models are:
Model 1: Greater involvement in primary care commissioning decisions within NHS England
This model envisages closer collaboration between CCGs and their area teams on decision making in primary care commissioning. As such, no new governance arrangements or special approval process will be required.
Model 2: Joint commissioning between CCGs and their area team
Under this model CCGs will assume joint commissioning responsibilities with their area team.
This will require CCGs to amend their constitutions to establish joint committees. The amended constitution will require the approval of members of the CCG and NHS England. Its proposed next steps slides state that a suggested model constitutional amendment is to be made available by NHS England after 1st October 2014 (when the legislative reform order giving CCGs the power to form joint committees with NHS England came into force).
NHS England will also need to be assured that joint commissioning proposals comply with the governance and financial framework for joint committees or committees in common which is being developed by NHS England in collaboration with CCGs and other key stakeholders.
Model 3: Delegated arrangements for CCGs to take full responsibility for commissioning from NHS England
Under this model, NHS England will delegate primary care commissioning to CCGs but as liability for such commissioning will remain with NHS England it will require assurance that such delegated arrangements do effectively discharge its statutory duty.
The CCGs will also need to satisfy NHS England as part of the approvals process as to how they will handle the increased number of conflicts of interests that are likely to arise for CCGs’ governing bodies and GPs in commissioning roles. Again, NHS England’s proposed next steps slides state that work is underway to clarify expectations on how conflicts of interest will be managed.
CCGs will also need to amend their constitutions to incorporate delegated commissioning arrangements.
Timetable for implementation
The proposed next steps slides include an implementation timetable. CCGs are invited (following working their members and area team to submit proposals to their regional office for joint commissioning on 30th January 2015 and for delegated commissioning on 5th January 2015. Amendments to CCG constitutions that relate solely to joint or delegated commissioning arrangements will be accepted at these points too. It is envisaged that any such arrangements approved by NHS England will come into force on 1st April 2015.
Scope of co-commissioning
NHS England is of the view that only general practice services should be within the scope of joint and delegated arrangements for primary care co-commissioning for 2015/16. It states that there may be scope in future years, after full engagement with the relevant professional groups, for commissioning of dental, community pharmacy and eye health to be included within the scope of such arrangements.
Currently, NHS England does not plan to allow revalidation and performer’s lists or individual practice or performance management aspects of contract management to be delegated as it senses that there is no appetite from CCGs to take on these functions. But this may change if CCGs change their minds.
There is recognition by NHS England in its proposed next steps slides, both that one size does not fit all and also that the degree to which CCGs may want to engage in the commissioning of primary care services varies. CCGs that do not currently want to undertake primary care co-commissioning may choose to do so in future years or to change the co-commissioning model that they use. The proposed next steps slides make it clear that if CCGs want to undertake delegated commissioning arrangements in 2016/17, their proposals must be submitted by 1 June 2015 for delegated budgets to be included in their allocations for 2016/17. It seems that however much CCGs manage to influence these proposals, primary care co-commissioning is here to stay should CCGs wish to use it.