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October - November 2015

Consultation response form

Setting the mandate to NHS England for 2016 to 2017

Consultation Questions

1) Do you agree with our aims for the mandate to NHS England?

Your aims seem laudable until funding is considered. Between 1948 and 2010, the NHS

had average real-terms annual growth of 4%. Since 2010, the average has been a

fraction of 1%. In addition, the service has had to save £20bn to meet the Nicholson

Challenge and fund the estimated £bn cost of the Lansley reforms. Even the modest

£8bn requested by the CEO of NHS England to facilitate the Five Year Forward View

has been called into question. If this mandate is applied, it will place the NHS in an

impossible position: having to deliver financial balance and significantly enhanced

services within a far from adequate funding envelope.

2) Is there anything else we should be considering in producing the mandate to NHS

England?

You should be considering why the service is falling behind on measures like the 18

week referral-to-treatment pathway and ambulance Red 1 and Red 2 response times,

and losing so many clinical staff. An honest consideration of this will lead you to the

conclusion that, without an additional £30bn a year by 2020, you are simply rearranging

the deckchairs on the Titanic.

3) What views do you have on our overarching objective of improving outcomes and

reducing health inequalities, including by using new measures of comparative

quality for local CCG populations to complement the national outcomes measures

in the NHS Outcomes Framework?

If you really want to improve outcomes, you need to start with patient safety and

implement the recommendation of the Mid Staffs inquiry that "standard procedures and

practice should include evidence-based tools for establishing what each service is likely

to require as a minimum in terms of staff numbers and skill mix". The SoS for Health

has recently prevented NICE from publishing detailed guidance on safe staffing. Until

such time as evidence-based safe staffing guidance is promulgated, including a

commitment to government funding, improved national outcome measures will not lead

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to improved outcomes. They will simply be another benchmark for the perceived failure

of the system.

4) What views do you have on our priorities for the health and care system?

1. Preventing ill health and supporting people to live healthier lives

It's difficult to see how this is consistent with your recent £200m cut in the 2015/16 public

health grant to local authorities.

2. Creating the safest, highest quality health and care service

Since you have chosen to make 7 day services a prominent element of this, I will confine

my comments to this element. The policy is based on a serious misrepresentation of a

BMA paper, about which even the editor of the BMA has protested. It wilfully ignores a

number of key requirements, the absence of which will cause significant patient safety

risks. These include the need for weekend social care services to support discharges

and an estimated 2% to 3% uplift in total NHS funding to pay for the additional medical,

nursing and support staff which will be needed to deliver the policy. Instead, the

government seems intent on taking the funding out of the pay budget, by cutting

unsocial hours payments for junior doctors and Agenda for Change staff and presenting

AfC annual increments as pay increases to justify freezing salaries. There is already a

shortage of GPs, nurses and paramedics. This policy direction will simply drive more of

these key staff away. None of this is consistent with priority 2.

3. Maintaining and improving performance against core standards while achieving

financial balance

I won't waste any more words on this, but will simply direct you to my response to

Question 1.

4. Transforming out-of-hospital care, ensuring services outside hospital settings are

more integrated and accessible

If you are serious about this laudable priority, you need to ask yourselves where the

GPs, nurses and paramedics necessary to deliver it are going to come from if you keep

making their lives so unpleasant and unrewarding.

5. Driving improvements in efficiency and productivity

Every organisation can find efficiencies and we must all keep looking for higher

productivity, but the NHS has had to deliver £20bn in CIP since 2010 and, while it

started well, in the last two years of the programme it became increasingly difficult to

deliver further CIP without affecting patient services. This has already resulted in longer

elective waiting times, unsafe staffing levels, loss of key staff and over-reliance on

agency and locum staff. The further £22bn CIP set out in the Five Year Forward View is

a step too far for an already overstretched service.

6. Supporting research, innovation and growth

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Interesting. In another context I would applaud this but I'm afraid that applause would be

rather muted in the current situation.

5) What views do you have on how we set objectives for NHS England to reflect

their contribution to achieving our priorities?

A good start would be to listen to the patients and the people delivering the service and

not resort to public warfare when you don't like the answers.