The next steps towards Integrated Care System development

The publication of NHS England and NHS Improvement’s Design Framework for Integrated Care Systems ahead of draft legislation, due in the forthcoming weeks, sets out minimum standards and expectations, and a timetable for development over the course of the transition period in 2021/22 and before ICSs become statutory bodies in April 2022.

In its basic form, the statutory ICS arrangements will comprise an ICS Partnership and ICS NHS body, with the Partnership aligning ambitions, purpose and strategies across system level and the NHS body operating in a way that reflects local context through place-based partnerships and provider collaboratives.

Over the coming weeks our team of integrated care lawyers will be producing commentary on the 56-page Framework document but in this article we provide an overview of the key points.

  • The Framework outlines the core features of every ICS while emphasising the need for local flexibility and determination.
  • We have details of NHSEI minimum standards in terms of membership of ICS bodies, their roles and accountabilities, governance and management arrangements, accountability and oversight, financial allocations and funding flows, and data standards and digital requirements.
  • On the composition of the boards of an ICS NHS body, the Framework details the minimum required with four executives, three independent non-executives and three partner members but beyond this the rules are flexible. NHSEI plans to publish further guidance on the composition and operation of the board, including a draft model constitution together with guidance on the management of conflicting roles and interests.
  • Further details for ICS Partnership boards will be published but the Framework does provide that the ICS NHS body and local authorities will need to jointly select a Partnership chair and define their role, term of office and accountabilities.
  • Senior appointments: the ICS NHS body chair and chief executives need to be in place by the end of September 2021 according to the implementation table. However we still await the publication of NHSEI’s guidance on competencies and job descriptions. This will reflect the “expected new accountabilities and responsibilities of ICS NHS bodies”. Note that the appointments to ICS chair and chief executive will be confirmed as “designate roles” subject to the progress of the Bill and after the second reading.
  • The Framework positions health and care providers at the frontline of each ICS. As members of the ICS Partnership, the ICS NHS body and place-based partnerships, providers will play a central role in establishing priorities for change and improvement across systems. The contracts providers hold (NHS Standard or national primary care supplemented locally) are expected to evolve to support longer term, outcomes-based agreements, with less transactional monitoring and greater dialogue on how shared objectives are achieved.
  • Further detail on the role of primary care in ICSs is included in the Framework.
  • Proposals cover the new provider selection regime which would see the removal of the current rules governing NHS procurement of healthcare services and replaced by a new regime specifically created for the NHS.
  • On provider collaboratives, from April 2022 trusts providing acute and/or mental health services will be expected to be part of one or more provider collaboratives. Community trusts, ambulance trusts and non-NHS providers (such as community interest companies) should participate in provider collaboratives where this is most beneficial for patients and makes sense for the providers and systems involved. Further guidance is expected on provider collaboratives but the Framework outlines a couple of contracting models.
  • The Framework provides that below system level, the ICS NHS body will be free to define place-based partnerships which best meet local needs. However the Framework does set out five place-based governance arrangements/models for the NHS body boards to consider adopting.
  • The Framework includes a table with indicative outputs expected from every ICS over the course of the transition period in 2021/22 (set out at page 51). This is subject to legislation and pending decisions on ICS boundaries.
  • Further NHSEI guidance is due to be published on supporting people transition planning and implementation. This will complement the publication of the guidance document on the employment commitment. We will be analysing this document in a separate article.
  • The Framework includes detail on the transfer of the functions and duties of clinical commissioning groups to an ICS NHS body, along with all CCG assets and liabilities including their commissioning responsibilities and contracts.


The publication of the Framework will be welcomed across the sector as it offers some clarity on the development of ICSs but with an element of flexibility to reflect local population needs something industry bodies, such as NHS Confederation have “consistently pressed for”.

Do get in touch if you’d like to discuss the implications of the framework for your system, place-based partnership or provider collaborative.

Our content explained

Every piece of content we create is correct on the date it’s published but please don’t rely on it as legal advice. If you’d like to speak to us about your own legal requirements, please contact one of our expert lawyers.

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