Leaked draft risk register reveals fears about CCGs going 'bust'

A loss of financial control, clinical commissioning groups (CCGs) going 'bust', an inability to negotiate the GP contract and GP leaders not being 'developed enough', are just some of the dangers if the Health Bill becomes law, according to a leaked draft risk register.

DH has refused to comment on the leaked risk register
DH has refused to comment on the leaked risk register

Fresh pressure is mounting on the DH to reveal the transitional risk register an information tribunal ordered it to publish on 9 March after a draft dated 28 September 2010 was leaked on Twitter last night by health writer Roy Lilley.

The leaked document reveals civil servants’ fears about changes being made before ‘transition plans’ are fully developed. It adds: ‘This could mean transition of some parts of the system starts on wrong basis, and subsequently proves to be wrong.’

They also express concern about loss of GPs’ clinical time, QIPP (Quality, Innovation, Productivity and Prevention) failure and increased difficulty in preparing for emergencies.

RCGP chairwoman Dr Clare Gerada said: ‘This is a document from 2010 and I would very much like to see a fresh risk register so we can understand what risks I and the rest of my profession are facing.

‘I am very concerned about some of the risks on the leaked risk register. These are some of the concerns we were raising at the time such as CCGs going bankrupt, GP capability and we were told that we were being cataclysmic.’

A DH spokeswoman refused to comment on the leaked document while health secretary Andrew Lansley is still refusing to publish the up-to-date transitional risk register until he receives the tribunal’s full decision. A spokeswoman for the Information Tribunal said this was now likely to be early next week.

This comes after the DH lost its appeal to the Information Commissioner’s Office ruling last November which ordered it to publish the ‘transitional risk register’ after a Freedom of Information request in 2010 by the then shadow health secretary John Healey.

But the tribunal backed the DH’s decision to keep the full ‘departmental risk register’ secret.

A DH spokeswoman said: ‘We do not comment on leaks. We have always been open about risk and have published all relevant information in the Impact Assessments alongside the Bill. As the latest performance figures show we are dealing with those risks, performance is improving - waiting times are down and mixed sex wards are at an all time low - and we are on course to make the efficiency savings that the NHS needs to safeguard it for the future.’

Others risks listed include:

  • Unable to negotiate the necessary changes to the GP contract to incentivise and lock practices into consortia
  • By dismantling the current management structures and controls, more failures, including financial, eg GP consortia go bust or have to cut services, and credibility of the system declines as a result.
  • There is a lack of clarity during the transition in terms of accountability
  • Staff concern and union action relating to certain workforce options result in deterioration in relations, lower productivity in DH / NHS; delays in programme.
  • NHS Commissioning Board is not sufficiently developed to assess capability of consortia. GP leaders are not sufficiently developed to run consortia for example, they may be drawn into managerial processes which drive clinical behaviour (rather than the other way around).
  • Inability to reduce running costs because of consortia  numbers
  • Financial instability in on-balance sheet providers if GPs successful in reducing hospital admissions
  • Increase in catastrophic failure with no system management
  • Inefficient co-ordination of communications. There is a risk that the DH will communicate in silos, with individual teams communicating about the transition without consideration of the wider implications.
  • There is a risk that the new system will be designed from an internal perspective, without taking into account the public/patient view. This could lead to an internally coherent system which is difficult for the public to navigate or hold to account.
  • Loss of financial control in the system through the transition process.
  • Failure to manage the costs of transition.

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