Children's organisations call for urgent updates to the Health and Care bill to focus adequately on children

Dear Secretary of State,

As part of the Children and Young People’s Health Policy Influencing Group, many of us met with officials from your Department to discuss the recent Integration and Innovation White Paper and the forthcoming Health and Care Bill. As a group of organisations with expertise on child health, we know how important integration and joint working is to improving outcomes for babies, children and young people. We fully support your drive towards integrated services and greater collaboration both within the health system and between the health system and its key partners.

The evidence is crystal clear that in order to achieve your goal of improving population health, tackling health inequalities, and preventing poor health later in life, there must be a strong focus on children and young people. However, we have serious concerns that these proposed changes have not been planned with children and young people in mind. By failing to recognise that children and young people are a distinct population who use a distinct health and care system with its own workforce, legislation and integration challenges, the reforms will not achieve the long-term improvement to health outcomes you intend.

Principally, we are concerned that:

The benefits of integration have only been considered from the perspectives of adults and the services adults use. Many of the proposals included in the White Paper will simply not apply to children and young people, including requirements on data sharing, discharge planning, direct social care payments, and other mechanisms of integration across health and adult social care. Our experience is that where the emphasis in legislation is on adults, children and young people are simply not considered when it comes to implementation.

There has been little focus on how the proposed changes will affect existing duties on the NHS and other bodies as they relate to children and young people. The Bill will transfer crucial legal duties held by Clinical Commissioning Groups (CCGs) onto Integrated Care System (ICS) NHS Bodies. Currently, CCGs have many key statutory duties relating to children and young people, including as lead members of multi-agency safeguarding partnerships and for jointly commissioning services for children and young people with SEND. We do not see any evidence that the careful planning needed to manage these changes has been undertaken.

There is a risk that children and young people will become invisible within Integrated Care Systems. There are currently no requirements to include key local leaders with responsibility for children and young people in ICS governance structures, and crucial services such as children’s social care and childcare and education will not be involved as a matter of course. Without this strategic involvement, the needs of children and young people will not receive the attention they require.

We cannot expect a system which has been designed with the needs of adults in mind to work effectively for babies, children and young people. We are therefore calling for the Health and Care Bill to be urgently updated to address these shortcomings in advance of it being laid before Parliament. We hope you will actively engage with children, young people and families as part of this process, as well as the organisations that represent them.

Yours sincerely

Amanda Allard,                                                            
Deputy Director, Council for Disabled Children                                          

Matthew Dodd
Head of Policy and Public Affairs, National Children’s Bureau

Co-chairs, Children and Young People’s Health Policy Influencing Group