We live by our principles to start with people and to be accountable to our people and communities in all that we do, including work around potential or proposed service changes. We’ve set out how the ICB and providers will work together with people potentially impacted by service changes in the ICB service change policy.
We also have oversight and assurance mechanisms to ensure that plans to involve are robust, effective and meet the four rules which underpin fair and meaningful consultation exercise – known as Gunning Principles. You can read more about these mechanisms in our Governance.
Statutory Duties
Integrated Care Boards have legal duties with regard to involvement which are set out in the National Health Services Act 2006, as amended by the Health and Care Act 2022:
- section 13Q for NHS England
- section 14Z45 for ICBs – ICB's role in ensuring that individuals are involved in the planning and development of commissioning arrangements and proposals for changes in commissioning arrangements
- Section 244 for NHS bodies – ICB’s role is to consult with HOSC
- Regulation 23 – Health scrutiny regulations
- Section 242 (1B) for NHS trusts and NHS foundation trusts
A requirement to involve the public is also included as a service condition in the NHS Standard Contract for providers.
NHS England and the Department of Health and Social Care have published new statutory guidance, Working in Partnership with People and Communities. It replaces the 2017 statutory guidance for commissioners, the 2008 statutory guidance for trusts and the 2021 Implementation Guidance for Integrated Care Systems.
As statutory guidance, this means that ICBs and trusts must have regard to it. We must consciously consider the guidance and, where appropriate, be able to explain any substantial departure from it. From this guidance and through local co-production events we have developed our involving people and communities approach to involve people and communities.
What are the 4 Gunning Principles?
Whether involvement is “fair” is primarily determined by reference to the Gunning Principles. The Gunning Principles can be summarised as follows:
(a) conduct the involvement exercise whilst the plan or proposal under consideration is still at a formative stage;
(b) provide sufficient information about the plan or proposal to enable an informed response;
(c) allow respondents sufficient time to consider the issues and provide a meaningful response;
(d) meaningfully take into account any feedback that is received as a part of the final decision-making process.
The Gunning Principles appear in both the old and new statutory guidance and their application to public involvement under the statutory duty to involve is covered in the new statutory guidance.
Case studies
Dudley Integrated Health and Care (DIHC) NHS Trust operates the High Oak Surgery from a modular portacabin in Pensnett. At the beginning of the COVID-19 pandemic, GP services were temporarily relocated from Pensnett to Brierley Hill Health &and Social Care Centre to make way for a respiratory assessment centre, which was needed for people with suspected COVID-19 symptoms.
Since 2020, several engagement activities have taken place with registered patients and local stakeholders about the proposal to relocate High Oak Surgery. In October 2022, with the support of colleagues from the ICB involvement team, DIHC launched a public conversation around the long-term, permanent location of the surgery. The activities were an opportunity for people to feedback about High Oak Surgery service following the relocation.
ICB involvement team colleagues supported DIHC Involvement colleagues with the facilitation of an options appraisal and supported the delivery of a comprehensive public conversation exercise by hosting informal drop in’s, co-hosting public meetings and helping people to complete paper or online surveys.
The public conversation came to an end 5 December 2022 at which point the feedback and findings were analysed by an independent third party. There was a strong preference for a surgery in the Pensnett area. People who responded to the public conversation expressed a desire for convenient and easy access to local healthcare services on foot or using local bus services, especially for older people or those with mobility problems or chronic conditions.
People expressed strong feelings regarding the local location of a surgery and its connection with the communities and individuals it serves. They elaborate on it being an integral and valued part of the community and their well-established and trusting relations with GPs and other staff at the surgery.
DIHC has since made a public commitment to ensuring that a GP presence is returned to Pensnett using the portacabin site in the short term while medium to longer-term solutions are scoped.
The ICB have worked with partners from a local hospital trust to shape the way services are offered at a Midwife Led Unit ahead of its refurbishment. Local women and families have had the opportunity to have their say on facilities within the unit and other ideas for improvements to help the Trust plan for the refurbishment, but also to understand what matters most to families when using maternity services and identify common issues or themes.
The ICB have supported in developing a survey in collaboration with the trust and their Maternity Voices Partnership, but also supported with targeted community conversations with local parent and baby groups.
The involvement team provide advice and support to GP practices across the Black Country on involvement with their practice population and on proposed service changes. This case study gives an example of the involvement team and GP practice working together to effectively involve patients in decisions about their practice, and how by using insight, the practice could make adjustments to minimise the impact this change might have.
The involvement team were contacted in September 2023 to support Lockstown GP practice as their branch surgery (Fisher Street) would need to vacate the building at the end of January 2024. The proposed closure of the building would have an impact on the delivery of services to patients from both sites.
The Involvement team advised the practice to complete a Health Equity Advice Tool (HEAT). The HEAT tool is a good starting point to identify the people who use the GP services and the groups of people who would be affected by this change. It would include patients and local stakeholders e.g. increased patients visiting the main practice site would have an affect on car parking used by other businesses near the main practice.
A member of the involvement team met with the practice manager and staff to assist the practice with its involvement activities. Follow-up regular telephone calls and virtual meetings were held to keep in touch for updates, support and next steps.
The practice manager, Lisa Wolverson, speaks about her experience of using the HEAT tool, she said: “At first the HEAT assessment tool felt quite daunting but working with the involvement team we were able to really identify groups of patients who needed a more personal interaction. While a text message would cover a large number of the patients on our practice list, we felt that letters were more appropriate for a proportion of older patients who may not regularly use their mobile phones. Public meetings allowed us to discuss any concerns with those affected and allow patients a voice. Our website was utilised to advertise the proposal and request feedback and the TV screen we have in our waiting area was a good way to inform anyone attending the practice.”
How did the HEAT tool make you think or communicate with your patients differently? “By identifying the diversity of our practice list size we were able to view it from their perspective. We realised that our ethnic population needed letters and posters in appropriate languages, and we also spoke with our local temple who conveyed the message to attendees. Our learning disability and dementia patients may not understand the changes and this could be unsettling so we contacted their carers to discuss the proposal and the impact of any changes for them. There was also the partially sighted who needed phone calls.”
What changes did you implement into the main Lockstown practice as a result of the responses/views of patients who took part in the survey? “Our survey responses were mainly focussed on appointment availability and the practice needed to communicate that there would be no change to the quantity we provided. We adapted the clinic times to allow us to see vulnerable groups, such as learning disability and dementia, at a time when the surgery was quieter. Our practice will now open on Wednesday afternoon with limited clinics to allow the GP to carry out their annual reviews.”
All the findings of the surveys and views were compiled into a report which was presented to the Primary Care Sub-committee (the decision makers) in January 2024 together with the application and completed HEAT tool. The report detailed the views of patients and stakeholders to enable the committee members to be satisfied that reasonable steps had been taken to listen to views about the impact of the proposed closure and assist patients.
The branch site closed at the end of January 2024. Patients and stakeholders received relevant communication advising them about the closure date of Fisher Street and the options available to patients to find alternative services.
After the involvement exercise, we spoke with the practice manager, Lisa Wolverson, to get her feedback on starting with people made to the involvement period. She said: “I believe that by following this guidance we were able to communicate quite comprehensively with our patient list leading to a smooth transition when merging the two sites. To date, we have received no negative feedback! The involvement team was a great support giving me step-by-step advice.”
