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The role of Planning under the new NHS System

The views in this blog are those of the author. 

Jeffrey Ng MRTPI is a Primary Care Lead – Estates at NHS Buckinghamshire, Oxfordshire and Berkshire West Integrated Care Board (ICB) and is the only planner at the ICB. Jeffrey is the winner of the RTPI South East Young Planner of the Year 2018, BAME Rising Star Award 2024, the commended RTPI South East Young Planner of the Year 2024 and  the finalist of the RTPI Young Planner of the Year 2020 and 2021. He is also the former Young Planners Trustee of the RTPI.

Last year, I wrote an article related to a “disconnection” between primary care and planning and my conclusion is that planning plays a key role to help rebuild the NHS system. There are a lot of changes in the NHS since the last General Election, including the abolishment of the NHS England, the new strategic commissioning role of Integrated Care Boards (ICBs) and the newly published 10 Year Health Plan for England. This comes to a question, what is the role of planning in the new NHS system?

The introduction of Neighbourhood Health Services

Neighbourhood health firstly appears in paragraph 27 of the December 2024 version of the National Planning Policy Framework (NPPF), which says a strategic policymaking authority needs to take a consistent approach to planning the delivery of major infrastructure, including neighbourhood health facilities. In the recent NHS 10-Year Plan, the Government sets out that the Neighbourhood Health Service will be a new era for GP practices by having a new public private partnership (PPPs) to deliver the facilities and new contracts for GPs to operate. Yet, none of the documents set out the details of neighbourhood health services and the proposed PPP model. It is only understood that  the proposed services will be operated by neighbourhood providers. This also appears that the proposed services will act as an “alternative” to the existing GP services, but it also covers other acute and community health services.

The NPPF requires a consistent approach to deliver the neighbourhood health infrastructure, but it is not clear whether it is the role of new ICBs or the proposed neighbourhood providers. The NPPF requires local authorities to review local plans from time to time. Planning is a live system, and local authorities are required to review and produce an updated local plan at a timely manner. Unless there is a clear definition of the role of new ICBs and the proposed neighbourhood providers, it is clearly a missing opportunity for local authorities to take in account any neighbourhood health infrastructure in local plans, which are the key documents shaping the development of local areas.

Challenges of existing NHS-GP funding and delivery model

Currently, primary care estates projects are funded by developer contributions if it can be demonstrated that a local GP Practice serving the new development is already over-capacity and the requested contribution will go towards a project which can increase the capacity of the Practice to serve the new population. However, there are challenges for ICBs requesting and using developer contributions to fund primary care estates projects. Firstly, they are linked with the progress of new developments and cannot resolve any existing capacity issues of GP practices. This implies that developer contributions would not be able to resolve any existing capacity issues. Secondly, GP premises are not managed by ICBs, and this limits the bargaining power of ICBs when requesting developer contributions as ICBs would need to work with GP partners and third party landlords to ensure the deliverability of the funded project(s). It is disappointing that either the new NHS system or the proposed changes in the planning system are not providing any changes to the existing NHS-GP funding and delivery model. Local authorities are also having challenges in allocating community infrastructure levy (CIL) towards primary care as there are already a number of council projects on the list and there is no legal requirement for local authorities to allocate CIL towards primary care. This remains a big challenge for ICBs to secure fundings and new health provision in the planning system.

New strategic commissioning role of Integrated Care Boards

Most of the ICBs are currently under restructuring and it is expected that there will be a smaller number of ICBs under the new NHS system.  For example, Buckinghamshire, Oxfordshire and Berkshire West ICB is going to include part of Frimley ICB to form the new Thames Valley ICB. From the ICB’s Blueprint document, the new ICBs will still have a strategic commissioning function of estates but it is not clear whether it will include the proposed neighbourhood health infrastructure and primary care. This also leads to a big uncertainty of the role of new ICBs in the planning system. It appears that the proposed neighbourhood providers and GPs will have to manage their own estates. However, it implies that there is a lack of coordination about how GPs and neighbourhood health centres are planned strategically. This also implies that local authorities and developers have to engage with individual neighbourhood health providers and GPs if ICBs are no longer the role of primary care commissioners. While the Government is promoting strategic planning and devolution to create a new layer of strategic authorities, it is not clear the role of neighbourhood health infrastructure and ICBs under the new authorities in ensuring healthcare is considered under the new authorities.

What’s next?

The proposed Neighbourhood Health Services shows that the Government is taking into account of the findings from the Lord Darzi’s report. However, the Government is seeking to create a new layer of neighbourhood health services instead of reviewing the existing primary care estates delivery and funding model. Sadly, the proposed changes to the NHS system do not provide any material changes to the existing GP funding and delivery model, in particular how to maximise the use of developer contributions to support primary care estates projects. It is also not clear about the role of ICBs and the proposed neighbourhood health providers under the ongoing reorganisation of local governments and the planning system. There is a need to review how primary care infrastructure is currently funded and provided as it is to ensure health facilities are “fit for purpose but also “fit for the future”, as set out in the Government’s NHS 10-Year Plan. There is also a need to ensure local plans take into account of health and primary care as it is an important piece of infrastructure and services to be delivered along with any new housing growth.