Editor’s blog Thursday 29 July 2010: Dear Comrades - Onward to the closures against which Comrade Lansley campaigned!
To borrow HPI new recruit Doctor X's marvellous phrase, this new 'Dear Comrade' letter from NHS Czar-In-Chief Sir David Nicholson puts some scant flesh on the bones of how smartly the service can now start shutting things.
In a GP commissioner-led manner, naturally.
Lansley's 25% genuinely measurable reconfiguration tests
Over two months ago, I pointed out that of Health Secretary Andrew Turquoise Hair Lansley's four tests for reconfiguration, only one was empirically measurable.
The other three are all opinions, or essentially subjective.
Be reasonable: do it my way
The 'Dear Comrade' missive thinks that the way around this fuzzy logic is to apply a "reasonableness test".
Yes, this is in a letter coming from the DH.
"In assembling the evidence, local commissioners will need to apply a test of reasonableness and consider, on balance, whether they can demonstrate to their SHAs (and could, if required, demonstrate externally to the IRP) that they have met the tests.
"Commissioners should consider the overall burden of proof for the service change. Whilst not all issues can always be resolved, commissioners must be able to show that they, and their partners, have taken every reasonable step to address any outstanding issues
Blessed are the troublemakers
Now one of the things the NHS sometimes gets spectacularly, wildly wrong is public consultation - a legal requirement, as the document notes.
It has not been entirely unknown for people who oppose reconfiguration decisions to be branded 'troublemakers', and for what appear to be concerted efforts to be made by the local and regional NHS to marginalise or ignore them.
The 'Dear Comrade' missive gives a hearty motivational boost to old-school NHS paternalists everywhere, with its lines, "If local stakeholders or individuals have concerns, they will need to provide valid and robust evidence to support their position. This is to avoid schemes which otherwise meet the four tests being delayed by potentially vexatious objections".
A big role for SHAs in policing GP commissioner-led reconfiguration? You don't say!
Czar-In-Chief Sir David is of course also justly famous as 'The Great Decentraliser'; Mr 'Look Out To Your Communities, Not Up To Whitehall ...Oh, Sorry, AND Up To Whitehall'.
And so without undue astonishment, we therefore find the following text in the 'Dear Comrade' epistle to the apostles:
"Local commissioners will need to demonstrate to their SHA that the tests have been applied and met ... SHAs have an important role in overseeing the application of the tests for new and existing schemes. They should assure themselves that local commissioners have developed sound, evidence-based proposals and that (where held) consultations are robust. SHAs should take a rigorous review of the evidence presented, including where commissioners report there are unresolved concerns and how they have sought to address these.
"Based on the evidence submitted by their commissioners, SHAs should undertake an assessment of which proposals have successfully demonstrated the tests and should proceed, which require further work and which (if any) should be halted. This initial assessment should have been completed by 31 October 2010".
It's tempting to wonder what HealthWatch would make of this - but of course, they don't exist yet.
And the CCP are going to be very busy people indeed!
We are also given to understand, "all reconfiguration schemes are already subject to the Principles and Rules of Cooperation and Competition (PRCC). Those reconfigurations involving a merger will therefore continue to be required to pass through a formal assessment by the Cooperation and Competition Panel (CCP). Where reconfiguration proposals do not involve a merger, commissioners must seek informal advice from the CCP on the patient choice and competition implications of their reconfiguration plans. This will ensure that potential breaches of PRCC can be identified at an early stage and the CCP can offer advice on the possible range of options open to commissioners".
Merging? Talk to the CCP. Not merging? Talk to the CCP.
Is Armando Ianucci writing this stuff? I think we should be told.