Does the current national regulatory approach positively support the implementation of the NHS Long Term Plan? A view from the board

17 October 2019


by Yvonne Mowlds Partner, Forensics Health Lead

Email +44 (0)7715 771381

by Laura Middleton Director, Forensic Services

Email +44 (0)7730 067252

It has been nine months since the NHS Long Term Plan (the LTP) was first published and organisations and systems have been considering how they can deliver on its ambitions. In order to understand its impact, and to gauge how well it’s being implemented, we surveyed  NHS Non-Executive Directors (NEDs) from across England and asked them to feedback on the regulatory approach, the effectiveness of governance and the impact of technology. 

In this blog we look in more detail at their thoughts around the regulatory approach. In fact we found that NEDs, in the main, do not believe that the current national regulatory approach positively supports the implementation of the LTP:


We have identified three key areas where improvements could be made:

  • The approach to finance

The national approach sets the agenda but organisations and systems are responsible for working together to achieve financial balance whilst delivering the LTP in challenging financial times. Therefore further clarity and guidance about the implementation of the LTP from national regulators, including approaches to sharing budgets and driving financial improvements without the same contractual levers as individual organisations have, may help to dispel feelings of frustration and apathy about national level regulation. 

Before the publication of the LTP, we undertook a review of finances in the health and care system in conjunction with the HFMA. We made a number of recommendations, including the immediate need for system wide control totals, merging of local health, social care and public health budgets, and a rethink of how capital projects are funded. 

  • Regional level of regulation and the regulatory structure of Integrated Care Systems 

Respondents to the survey raised concerns about disjointed approaches to regulation, inconsistency in performance targets for different organisations and there being too many separate legal entities causing issues in the implementation of the LTP and the successful implementation of regulation.  

As NHSE/I embed their new operating model and approach to regulation/performance management and improvement this is something we believe will need to be addressed to give system leaders a real opportunity to drive at pace the transformation and change required to deliver the 10 year plan. Similarly, clear guidance to help organisations to navigate system working without legislative change to support this would be beneficial in the short term.

PwC, working in partnership with Optum Health, recently concluded a leadership development programme, which aimed to support system working and accelerate the transformation journey in aspirant ICSs. We worked with some of the largest ICSs in England and with CCGs at various stages of maturity and integration. A key theme arising from this work was the need to focus on a unified purpose, culture, behaviours and ways of working, not just on regulation and organisational form. 

In a recent blog on the implementation of the LTP, Mike Farrar, PwC NHS NEDs Programme Chair describes the need for “capable management, with wide creative and collaborative mindsets”. As leaders, executive and non-executive continue to navigate the ever changing health and social care landscape focus on these areas will become even more important if the LTP is to be delivered.

  • Workforce issues

The NEDs reported a high level of confidence with regard to their own organisations’ preparedness to deliver the LTP. However, there were a number of challenges highlighted by respondents. Unsurprisingly, workforce was noted as a key concern, and in particular, high levels of vacancies amongst clinical staff. Whilst everyone would agree this is not an easy problem to solve, we believe there is an opportunity for the health and social care system in the UK to invest in technology and data analytics to support the delivery of services in a new way with a different shaped workforce. 

However, a change in mindset will be required to embrace and maximise the opportunity technology and data brings to our desire to deliver a sustainable, high quality health and social care service. Our research sets out some key learnings from our work with the care home sector that may also provide some food for thought in the wider healthcare sector.

Read ‘What are the challenges for implementing the NHS Long Term Plan? NHS Non-Executive Directors survey 2019’ here.

by Yvonne Mowlds Partner, Forensics Health Lead

Email +44 (0)7715 771381

by Laura Middleton Director, Forensic Services

Email +44 (0)7730 067252