Latest / Embedded / What “Contract-Ready” Really Means | Embedded Conversations With Alison Oliver. Ep 3

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What “Contract-Ready” Really Means | Embedded Conversations With Alison Oliver. Ep 3 · Embedded

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Welcome to Embedded Conversations, the podcast that explores what it takes to
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embed ideas, innovations and partnerships inside the NHS.
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I'm Scott McKenzie and I work with NHS leaders, commissioners and life science
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companies to change patient pathways for the better.
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This podcast brings those ideas to life through shared stories from people inside
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the system who talk honestly about what works, what doesn't and what it takes
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to embed change in the real world.
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If you're working in, around or with the NHS and you want to understand how
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change really happens, you're in the right place.
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Good morning everyone and welcome to the latest Embedded Conversations.
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Today I'm really pleased to be joined by Alison Oliver.
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Alison is a partner at Sintons LLP and in my opinion is one of the leading experts
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in the UK on healthcare including partnerships, contracting and governance and,
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I've worked with Alison over many years.
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Where she works with NHS organisations including things like general practice,
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the primary care networks, neighbourhoods,
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NHS trusts and of course GP federations as well which is how I first,
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met Alison and what Alison does brilliantly is help people navigate what are
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increasingly complicated and complex commissioning and provider landscape.
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So in her role she brings a really vital and very practical perspective on what
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the changes really mean for primary care, for secondary care and of course for
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industry partners that might want to support them.
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So today whether you're leading a neighbourhood, supporting a primary care network
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or you work in pharma and MedTech or devices,
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this conversation is going to bring you insights into what's coming next and
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what it really means to be ready when those new provider contracts arrive and start to take shape.
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So Alison, good morning. It's an absolute delight to have you here with me.
1:59
Good morning scott thanks very much for having me oh no it's a this is a,
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i think for some of the people that i've kind of talked about and said oh a
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legal person oh that'll be interesting and it's primarily i think because,
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most of them don't really come across you in your role you're kind of in the
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background unless you're working with the the front line so i think you've got
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some different insights to bring
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to the party today that's what i'm hoping we'll be able to get out of you,
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great yep so if i start um with what's changing it's like oh there's a big long
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list isn't it we're hearing more and more,
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about single and multi neighborhood provider contracts i know we haven't got
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the contracts yet and we don't quite know when they might arrive probably the
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31st of march if it's the standard,
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and timescale but with what we know now could you explain kind of what they
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are, how they fit into the wider shift we're seeing in NHS commissioning police.
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Yes. So, the idea of single and multi-neighbourhood provider contracts was first
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mentioned in the NHS 10-year plan, which was published last July.
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And as you said, we're still waiting for the details. So, I think we'd all hoped
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that we would have a lot more information at this stage than we currently do.
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But what we have been told from
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the 10-year plan and some very high level information following is that,
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single neighbourhood providers will provide enhanced services across neighbourhoods
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of around 50,000 patients,
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and multi-neighbourhood providers will deliver care that requires working across
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several neighbourhoods such as end-of-life care,
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and the whole idea of the single neighbourhood and multi-neighbourhood working
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is really a continuation of the general shift that we've both seen Scott over
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a number of years towards,
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primary care services being delivered at greater scale together with an emphasis
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on moving more services out of hospitals and into local communities.
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I mean funnily enough the last podcast recording that I did,
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really reminded me of working with you because you will remember the very first
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hospital subcontract that we did before left shift was,
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even a thing with Paul Nets up in Newcastle upon time when we shifted that work
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out the hospital Paul was my last guest on the the podcast talking about that
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and I mentioned him to you
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him uh you to him in that that conversation because it was before it was even
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in vogue it was even a thing where we're doing left shift which was brilliant,
4:32
yeah yeah that's right yeah yeah,
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and one of the things that comes up I think a lot in my work from a legal perspective
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we get We hear the term that primary care networks and federations particularly
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need to be contract ready.
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What for you are the key steps that they should be taking now in terms of things
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like their governance, their structure, probably their risk management as well? What are those things?
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Yeah. So, I mean, one of the key things is because we have been told that,
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the commissioners are likely to be able to commission these services from other
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providers if primary care isn't able to step up and deliver these services,
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then one of the things that ECNs or federations need to do is demonstrating
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that they have the capability and the expertise to deliver the services.
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I mean, that's the most basic thing, isn't it, when you're having to kind of
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competitively do something.
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So they should be able to demonstrate that they're able to mobilize a suitably
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qualified workforce and have effective clinical governance systems, etc.
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Another thing is actually something we were chatting about before we started
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recording the podcast, Scott, and that's about, for PCNs in particular,
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looking at their geographical configuration.
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Because we've been told that the single neighbourhood provider contracts are
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intended to cover a geography of around 50,000 patients and,
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The general range is sort of 30,000 to 50,000 patients. Now,
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we have had some smaller and some bigger than that.
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But PCNs that perhaps aren't in the 50,000 ballpark might have to start looking
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at whether they need to reconfigure and perhaps have some discussions with the
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ICB locally around that.
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And also, if they're not, you know, what we've termed geographically sensible.
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So you'd mentioned when we were chatting earlier about donut pcns so a piece you know a pcn where,
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you have a big hole in the middle and the hole in the middle practices might
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be part of a different pcn or not in a pcn at all so when you're looking at the new neighborhoods,
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as determined by the commissioners the pcns as far as possible need to try and align with that.
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And then another aspect is about just having the right sort of organizational structure.
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And this is kind of the boring legal bit that I do in the background that nobody
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really wants to think about.
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But one of the challenges that we've had for PCNs is that they,
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were contracted on the basis of, rather than a single contract being given to
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an organization, it was multiple GP practices being contracted to provide services
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through the directed enhanced service, which is a variation of their core primary care contract.
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And that meant that PCNs aren't actually legal structures.
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They're just informal networks of GP practices who each individually have signed
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up to the network contract directed enhanced service under which they are collectively
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responsible for delivering the services.
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And that's presented some real challenges for PCNs. So, for example,
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they don't have a legal entity that can employ staff.
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Um they there is an obvious easy way of managing risk um which comes with collaborative working,
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and we have seen some pcn's forming limited companies so that they've got a
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vehicle to employ pcn workforce rather than the individual practices having to bear that risk.
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But there are lots of pcn's that don't have that corporate vehicle now my view
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is that most pcn's should be thinking about that because if do a single neighborhood
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contract that isn't commissioned via that DES mechanism.
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Then you're probably looking at having a single NHS standard contract being
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offered across the whole neighborhood which,
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I wouldn't be advising individual GP practices to sign up to it'd be far better
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to have a legal corporate structure with its own legal personality and with
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limited liability for the practices within the network.
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And again I suppose with Sorry, carry on. No, go on.
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I was just going to say that just another caveat to that was that in some areas
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where we have established GP federations,
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they might be able to hold those contracts for the neighbourhoods within their
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region and perhaps kind of subcontract the delivery to the practices so that
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that income stream is still preserved for practices.
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But if there isn't a federation in the area, and there are still quite a lot
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of areas that kind of multi-neighborhood level that don't have an established
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federation company they should be thinking about doing that as well.
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So you've actually answered the question that I was was going to pose this is the maybe,
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another great role for the for the GP federations particularly where they're
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up they're running they've got experience they've had they've already holding
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NHS contracts or subcontracts as we touched on just prior to this.
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That could be an absolutely great role if you for particularly for the multi-neighborhood,
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actually some of our what some of our federation clients are doing now is is
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sort of looking at their their constitution and,
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governance structure to see if they need to kind of realign that review that
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and realign it to that new way of working that kind of no neighborhood way of working um,
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so that's another thing if they're you know if you are an existing federation
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and you've been used to working in a particular way,
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you might want to have a bit of a refresh of your constitution just to see if
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it needs to be kind of rethought a little bit to make it more appropriate for
10:19
this new way of working it's interesting,
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this conversation i'm smiling there just now because i'm literally getting approached again,
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scott could you help us put together a gp federation i've even got a couple
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of areas where they had them folded them and then i want to restart them again
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for the very reason that we're talking about so yeah that could be another one
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of those interesting developments ahead.
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Um and that kind of leads neatly into the next question that i've got for you which is,
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i find really that bit that we're just talking about just now which i would badge as governance,
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making sure the decision making is transparent it's representative of the member
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practices and of course it's legally sound,
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what does that good governance look like in practice And how do the PCNs and
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the federations and ultimately neighbourhoods build structures that commissioners would trust?
11:09
Yeah, so this is really important because it's something that commissioners
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need to satisfy themselves about. They want to make sure that,
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particularly if they're looking for organisations that are representative of.
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The practices within that locality. So there are various accepted pillars of good governance.
11:30
So governance structures should be participatory, transparent,
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as you said, accountable, responsive, efficient.
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And follow the rule of law. So in practice, participatory governance essentially
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means ensuring that members are informed and have a voice and that members and
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stakeholders are able to access benefits in a fair way.
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Unfortunately, we do come across PCNs and federations where the leadership team
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works in a silo and the members aren't engaged or aware of what the organisation is doing i've even had,
12:04
um i've even had practices coming to me and saying we need to form um,
12:09
a company for our area and they've actually already got one but the leadership
12:14
of that organization is so detached from them that they they don't really understand
12:19
what what they're doing or why or,
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um or feel that they have any stake in that organization so so that kind of
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engagement is really, really crucial.
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And that means kind of sharing information, ensuring that the members and other
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stakeholders are given the opportunity to make their views heard.
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And that really needs to be baked into the constitution of the organisation, but also,
12:43
lived in practice it's not enough to just write it down on a bit of paper that's
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it again it's a great point because
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again i learned from you way back at the beginning and it was one of the things
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that i tried to engender into the boards of the federations that i work with
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and support i still do to this day,
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and i've got some where we have,
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quarterly member membership meetings and the membership are asked you know is
13:07
there anything specific that you want to know about this of an update as you
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you drive the agenda we've got things that we want to bring to you,
13:14
but we absolutely want to engage you in the agenda setting so they're really
13:17
well attended because people know,
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this is where i get a chance to have a say this is where i get an update i'll
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then know exactly what's going on so all of that is part of for me good governance
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and running a federation but as i say that was really the learning at the beginning
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whether what you don't want is a siloed board
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where people don't actually know what the board is working on no absolutely
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really and it links to the principle of transparency as well so,
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decision making needs to be open and visible and leaders should be accountable
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for their actions and ultimately ultimately the membership should be able to
13:50
challenge and even replace the leadership if i raise that all the time all the time.
13:56
That it's in the shareholders it's not a gift but,
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it's enshrined in company law that if you if you want to you can raise the issues
14:05
with the board and you can challenge them but it's part of what being a shareholder is all about,
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is getting you don't want that happening all the time but if you really thought
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the board was behaving inappropriately there is a mechanism there but most people
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don't have an awareness of that
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no exactly yeah um just just coming back to the yeah about good governance i
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mean i think i think one of the things that often gets overlooked as well,
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um is efficiency um,
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so you know we're working in the health care system with a very limited budget,
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um and it's really important that resources are utilized responsibly um,
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and that risk is managed effectively so that you don't get wastage of that very
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precious um health resource um.
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And And finally, following the rule of law, another principle of governance,
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it basically means that systems should be clear and fair and applied equitably.
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So there's kind of a thread running through all of this around transparency,
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fairness, openness, transparency.
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And that really needs to be the case because as federations and PCNs,
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potentially PCNs, and again, you've just flagged, really wouldn't want a PCN
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signing up to that. I'd want them to have a legal entity for all the reasons that you've given.
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But as they start holding those larger, more complex contracts,
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there can be quite significant legal risks that they need to be aware of.
15:27
I would say things like 2P, you know, so the transfer under protected employment,
15:32
indemnity is a huge one, data protection, cyber security, things like that.
15:37
How do they manage those risks effectively from your perspective but still be
15:42
able to be agile and to respond to the opportunities.
15:47
Yeah, it's a really good question.
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So health resources are very human resource intensive. Intensive, yeah.
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And so some of the main risks for providers working at scale are workforce related,
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particularly if you're kind of sharing staff for different organisations and so on.
16:09
So, I mean, employment law is such a complex area. I'm not an employment lawyer. Yeah.
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And the penalties for failing to adhere to employment law can be quite high
16:21
and it can be quite costly, both in financial terms, but also in kind of just organisational stress,
16:30
if you don't manage your employment arrangements well. So it's really important,
16:35
to make sure that you are informed and take the right advice at the right time
16:39
when you're dealing with workforce issues.
16:42
You mentioned 2P, yes, and that's a major concern when there are changes in
16:46
service provision, which is quite often what happens when you have these large,
16:49
more complex contracts.
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You have a lead provider subcontracting to the provider and then that ends and
16:58
it changes to another provider.
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And every time there's a service contract change like that, TUPI will often
17:06
operate to transfer the workforce engaged by the outgoing provider to the new provider.
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And the way that TUPE works is that all the historic liabilities transfer with the staff.
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So you really need that contractual protection from the outgoing provider so,
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that they identify the provider against those historic employment liabilities.
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And there are also penalties under 2P if, you know, that 2P requires that the
17:35
employers inform and consult the staff when there are going to be changes in
17:39
their employment and there are quite onerous penalties for failing to adhere to those obligations.
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In terms of other risks, you mentioned data protection and data sharing is a
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massive risk when you're working collaboratively.
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You've got, you know, most providers of healthcare will control sensitive personal
17:59
data about their patients and then as part of their collaborative working range,
18:05
they may well need to share that with other providers.
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So if you have a provider like practice they share patient data with a third
18:13
party subcontractor and that third party commits a data breach,
18:19
the practice could be exposed to claims by patients or regulatory sanctions
18:24
or action for breach of their nhs contract and that's not to mention the reputational damage,
18:30
that's the key one things like increase and dreams so it's really really yeah
18:34
really important that when you're um if you are going to share data with another
18:38
provider you carry out due diligence on those,
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um third parties to ensure that they've got proper data protection measures
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in place and you should always always have a data sharing agreement um which
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sets out clearly how the data can be used and then the responsibilities of,
18:55
qualities in relation to that data um and crucially having some remedies in
18:59
there for the controller if the other parties commit a data breach.
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It makes me wince just thinking about what that's like if there's a data breach.
19:08
Yeah, it's terrific. Yeah, it is. It really is.
19:12
It's one of those things where you just, you have to, I think it's not a lot
19:15
of people say, oh, I hope we never need that.
19:17
No, I work the other way around. We want to make sure that this is how we work
19:22
so that we never need it. You can't just sit there and hope.
19:24
It really needs to be part of the system and process that you put in place,
19:27
which I think is really what you're saying.
19:30
Yeah, absolutely. Yeah. Of course, alongside all of that, we've got the industry.
19:37
So pharmaceutical, medical technology and device companies who all want to collaborate,
19:42
with the NHS, particularly more and more around pathway redesign,
19:46
things like diagnostics, the left shift, the community-based services.
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If I asked you there from a kind of legal standpoint, what makes these partnerships
19:56
safe, transparent, sustainable, really within those kind of governance frameworks
20:00
that you've just touched on.
20:03
Yeah absolutely so I mean these kinds of collaboration are becoming more and more common,
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as you know Scott and they can be a really great way of developing innovative
20:14
and integrated solutions,
20:16
that improve outcomes for patients so they can be really important part of the
20:21
overall healthcare landscape but there are challenges when you have collaborations between,
20:27
different organizations, particularly when they might be working in completely
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different sectors and they're subject to,
20:34
different regulatory regimes.
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And as we've just been talking about, data sharing, you know,
20:41
is obviously something that needs to be thought about when you're having that kind of collaboration.
20:46
But also intellectual property management, that needs really careful planning and good governance.
20:53
It's the intellectual property that's developed as part of the collaboration,
20:57
how to license it between different collaborators.
21:02
Um shared goals i think it's really important that everybody knows exactly what
21:07
what they're collaborating for and why um,
21:11
communicate effectively with each other um and really crucially have clarity
21:16
about the scope of their respective roles and authority,
21:20
in relation to the collaboration and and again i'm going to talk about the boring
21:24
legal stuff the the documents that you hope you never have to read but you really
21:28
do need some kind of collaboration agreement,
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so that you're setting out exactly what the roles of parties are,
21:34
what their respective rights are, what their,
21:37
respective responsibilities are, how you're going to share risk and benefit
21:42
because it's really fertile ground for disputes.
21:46
Yes, and that's what you don't want. It's one of the things that I really enjoy
21:50
about working with you. You say it's the boring legal bits.
21:52
I tend to look at it as, no, that's going to be the system and process that we live by,
21:57
because if you embed it as the way that you work, there's much less risk of
22:00
it going wrong what i tend to find that goes wrong is when we get all the documents
22:05
done and we kind of go yeah we'll sign them off right put them on the shelf
22:07
and then now we're going to go and do our own thing
22:09
that's where it tends to go wrong whereas if you're very open
22:13
transparent and you embed a system and process
22:16
in the way that you work that reflects the governance that you've just signed
22:19
off on you tend not to have problems would that be your experience as well,
22:24
absolutely yeah yeah yeah cool that's good i mean it certainly helps it does it does.
22:30
I'm going to ask you to do a bit of crystal ball gazing.
22:33
If we look ahead, and I get, you know, every week there's a new document,
22:37
there's a new policy, there's something else, but if we look at the way that
22:41
the NHS is evolving, kind of regionally, contractually, maybe some might say culturally,
22:48
what do you think this landscape is going to look like by the time we get to
22:51
the end of this parliament, 2930?
22:54
And will we still have PCNs and federations? Will they have a role to play?
22:59
What would you be advising them to do that will keep them ahead of the curve?
23:04
Yeah, good question. So, I mean, in the time that I've worked in this kind of
23:10
role, I mean, about 20 years, the NHS has changed so much. Yeah.
23:15
So we've had, you know, primary care trusts and then they were replaced with
23:20
clinical commissioning groups and then they were replaced with integrated care
23:23
boards covering much larger areas.
23:27
And a lot of this is about increased scale. So, you know, I mean,
23:30
particularly when you're looking at the ICBs compared to the CCGs.
23:34
But also in the size of the providers.
23:36
So if you're looking at GP practices in the formation of federations,
23:40
when we were working together first, Scott, and then the PCNs,
23:44
a lot of the changes in this period have been about increased scale.
23:48
Yes um also about um collaboration that we've talked about so it's a you know
23:55
like it about working with other parts of the health care system more effectively,
24:00
um and that's a theme been a theme of a lot of the the policy output that we've
24:05
that we've seen over recent years and then the direction of 10-year plan is
24:10
again a much greater focus on moving services into the community,
24:15
the introduction of neighbourhood and multi-neighbourhood contracts to support that.
24:19
And in terms of the role of PCNs and federations, well, they obviously have.
24:24
A really you know good opportunity to occupy that space PCNs generally,
24:29
yeah could align with with the neighborhoods although as we talked about before
24:33
they probably are going to need to be there's going to be need to be a bit of
24:36
reconfiguration but they're in a good place um,
24:40
federations working at that multi-neighborhood level obviously have a good opportunity
24:45
to to to compete to to hold those multi-neighborhood contracts,
24:50
um but I think one of the main problems with with primary care generally at
24:55
all levels whether it's at practice pcn or federation level is that primary
25:00
care often does lack the infrastructure and leadership to plan ahead.
25:05
Yeah and there's a risk in that in that environment that other providers will
25:10
take those opportunities um if general practice doesn't.
25:14
It doesn't step up um and i do i do know it's hard you know because they're
25:18
much more organizations you know but it's um,
25:21
in terms of what they can be doing to prepare well i mean it's it's it's very
25:26
difficult because primary care is going to be dependent a lot of the time on
25:30
on other parts of the system you know for example if you're looking at neighborhood health centers
25:35
yeah um most gp practices aren't in a position to build a neighborhood health
25:39
center so they are going to have to be kind of looking at other,
25:42
you know working with other parts of the system to make sure that they can address things like estate.
25:48
But in terms of what they can be doing themselves, as I mentioned earlier,
25:52
getting a legal structure getting
25:53
your own house in order yeah making sure that your constitution is is.
25:59
Correct is the correct type of constitution for for what you want to be doing,
26:04
going forward they're all good first steps yes and and,
26:08
it was one of the key things i took away from you because i remember i've been
26:11
the same 20 years as you it's kind of ironic but that's literally the case so
26:15
the right back at the beginning it was pcts and practice-based commissioning groups
26:20
and then as we moved into clinical commissioning groups we had the development
26:23
of GP federations which was really where I first met you was,
26:27
looking at how I could help people structure that governance and decision making
26:32
and engagement and such like and then we rolled that forward into really the
26:36
end of CCGs and the development of primary care networks which now sit with
26:40
ICBs and we're now going to see neighbourhood teams and all the way through that,
26:44
those at scale GP federation providers have continued some have been thrived
26:49
some of them of course have come and gone so,
26:52
i think you're absolutely spot on i think there is a great opportunity here
26:55
for for general practice but,
26:58
it needs to be able to step up and it's got to be able,
27:01
to do it coherently you can't have a hundred different voices you can't even
27:04
have two different voices you've got to have one very coherent structured voice
27:09
or i fear you will be absolutely right someone else will fill the void yeah
27:12
and And it's, you know, and a lot of it is about mindset, isn't it, Scott?
27:16
You know, because I think a lot of practices, because they have such a big workload,
27:20
it's difficult to be outward looking.
27:22
Yeah. And the introduction of primary care networks was a clear statement of intent. Yes.
27:29
By NHS England to try and, you know, encourage, shall I say,
27:34
inverted commas, that collaborative working. Yeah.
27:37
And I think primary care networks have, to some extent, helped to achieve that. Yeah.
27:42
It is about having that collaborative mindset a lot of the time,
27:46
which can be difficult when your day job is so hard.
27:49
I think a lot of it, I've observed this for many years with the federations
27:53
and now with the networks,
27:54
it's the willingness of the individual practice to kind of let go a little bit
27:59
of the autonomy and the decision making to that at scale organisation and being
28:04
prepared to follow rather than challenge everything that comes back the other way.
28:08
It's that would be my observation it's just that you're going to let go a little
28:12
bit of your autonomy and your decision making in return for hopefully a much better outcome,
28:18
yeah I've got one last quick question for you if I could give you a magic wand,
28:24
and there was one aspect of NHS contracting overnight that we could change what
28:28
would it be and why would that be your choice.
28:34
Mm-hmm. It's a really good question and a bit of a mean one.
28:38
It's not a mean one. Sorry, I didn't mean it to be mean.
28:42
I do think that the whole system is very complicated. It is, yeah.
28:48
And quite confusing for patients. You know, you have multiple different providers
28:53
all contracted in different ways and, you know, the system doesn't really,
28:58
different parts of the system don't really talk together as or to each other as much as as they,
29:04
they need to you know I can remember when I was pregnant having to carry my
29:08
bits of my maternity record around with me in a you know in a scruffy plastic
29:14
paper paper folder and and I'm not sure you know I mean although we're not,
29:18
working with those bits of paper so much anymore I'm not sure that you know
29:22
we're that much far advanced in terms of um,
29:26
how different parts of the system talk to each other and that's a bit unkind
29:29
because i think it has improved it's improved but,
29:32
i think there are still gaps yeah but i do think it's i think you know as a patient you know
29:36
i'm somebody who works in within the system and has an understanding of contracting
29:40
mechanisms and still myself as a patient i'm sometimes a bit confused about
29:43
who i should be talking to about what if i'm talking about my own um personal health,
29:48
um so i do something how much simple it would be if everything was done under
29:53
the umbrella of a single nhs organization without the need for multiple patient
29:57
records and complex procurement and contracting arrangements between different parts of the system.
30:02
But that's my head in the clouds. That could be a conversation for a different day.
30:09
We could just about do that. Because it is a great point that you make.
30:15
So I remember, again, going back to some of the subcontracting things where,
30:20
not that we forgot about the patient, don't take it that way,
30:22
anybody listening, it was never that. It was very, very, the whole point of
30:25
the redesign was patient focus. But,
30:28
i'm not going to name names i'm not even going to talk about areas the thing
30:31
that i remember more than anything was when we asked the patients for feedback,
30:35
we were hoping that we'd get this overwhelming positivity about the service,
30:40
yeah because it really was it was a very intricate redesign it moved hospital
30:44
work into the community but it brought the consultant with it so the consultant
30:48
and team were based in general practice alongside the gps,
30:52
and we were really excited about that as you know working as a team when we
30:56
asked the patients for feedback you know what the top feedback was.
30:59
There's a free car park because it's based in general practice.
31:02
There's a bus stop right outside the practice. And actually,
31:04
there's a tram stop at the end of the road. So it's fantastic.
31:08
It makes it much easier. It was none of the things that us as providers would
31:12
have thought would have been important.
31:13
It was all about ease of access and not having to turn up two hours early.
31:18
I remember that. I don't have to go two hours early to find a parking space,
31:22
at the hospital anymore.
31:23
And we often forget that, that from a patient perspective, as you've just cited,
31:27
that's get in get seen quickly get fixed and get back to life are kind of the
31:33
same information to lots of different people i think that that's crucial isn't it,
31:38
but i mean in terms of you know a more you know that's obviously a head in the
31:41
clouds answer and and um back in the real world i think,
31:45
in terms of what i would change from a contracting perspective um i suppose
31:49
i'd like to see a bit more consistency and approach yep yeah between commissioners
31:53
in different parts of the country so,
31:55
i do i completely understand and think it's important that that we have locally
31:59
tailored services local population needs and the integrated care boards are
32:04
in a far better position to to do that than than you know a national organization,
32:10
but i do in my day-to-day work come across quite marked variations between how
32:14
different icbs interpret the contract regulations,
32:19
which aren't necessarily related to local needs so for example um if a practice
32:23
wants to apply to incorporate its practice into a limited company um.
32:29
You know there's there's a mechanism and a policy and a procedure for that set
32:32
out in the policy and guidance manual,
32:35
but we still see hugely varying interpretations of that by different icbs different
32:40
parts of the country and that can make it very difficult for me as an advisor when i'm talking,
32:46
to clients about their options, it's quite hard for me to kind of say, well,
32:51
this is what will happen because,
32:54
We don't necessarily know because different ICBs have different approaches.
32:58
So, yeah, so I'd say that would be the thing from my day-to-day work that I
33:02
would find. That's a great answer. And it's one I recognise as well.
33:07
There are times, in fact, I feel a little degree of empathy with the ICBs where
33:12
they've inherited three, four, five CCGs now, particularly with the clusters.
33:17
And we've got exactly the same services running in general practice for argument's
33:21
sake, but they're being paid six different amounts across the pack.
33:24
You see that repeatedly. So I do have a real empathy with what the ICBs are inheriting.
33:30
So I would share your magic wand. Could we get a bit more consistency? We'd be brilliant.
33:35
Alison, thank you. I'm sure there are going to be people that are listening
33:41
who might want an introduction to you, so they can always come back to me and I'll be happy to do that.
33:45
I can get people connected if you have got questions or you've got things where
33:49
you think Alison could help I'll be delighted to do that and I'm sure Alison
33:53
would be delighted to speak to you as well,
33:55
but I just wanted to say a massive thank you from me and from everybody that
33:59
listens I'm so grateful to you for your time thanks again for joining me Alison.
34:03
Thanks Scott thanks for inviting me it's been a pleasure. Thank you.
34:07
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