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Nudge or fudge?


Despite covering everything from planting trees to cycle lanes, the White Paper on Public Health is much stronger on rhetoric than it is on detail, especially embracing the idea that people will make healthy decisions for themselves, given encouragement. What these policies will mean in reality will not be clear until a series of further documents are published in 2011.

The Government published a White Paper on Public Health yesterday, titled “Healthy Lives, Healthy People”, openly aimed at addressing the “lifestyle driven health problems” – citing obesity, alcohol and smoking - which are behind so much of the demand on the NHS.

As with the rest of the NHS reforms agenda, the emphasis is on the choices made by empowered and informed consumers. The approach advocated is to “nudge” them into making the healthy choice, rather than simply telling them what to do, decried as the “Whitehall diktat” or “nanny” state approach of the previous Government.

Key proposals

  • empowerment of local leadership and greater responsibility for improving health and well being across society
  • greater focus on key outcomes with an emphasis on transparency and accountability through a proposed new public health outcomes framework
  • feedom for local authorities to innovate to tailor solutions to their communities
  • ring fenced public health funding from within the NHS budget, with a new health premium rewarding local authorities for progress against proposed public health outcomes
  • emphasis on partnership working, with local authorities given responsibility for promoting the development of new commissioning strategies

Some of the key principles – such as moving responsibility for public health to local authorities - were heavily trailed in the preceding White Paper “Liberating the NHS”, which set out plans for the abolition of PCTs and SHAs, with their responsibilities to be redistributed between local authorities, consortia of GPs, and a new National Commissioning Board.

Hopefully 2011 will see a clear delineation of respective roles, where currently there is uncertainty. For example, we do not know yet who will deal with Continuing Healthcare, Offender Healthcare or Individual Funding requests. Public health may prove to be only a small part of the wider healthcare responsibilities that local authorities eventually assume.

“Healthy Lives” confirms that there is to be a new “integrated public health service” – Public Health England – from 2012, as part of the Department of Health. A crucial co-ordinating role will also be played by local Health and Well-being Boards, which will be a statutory requirement in each local authority.

“Localism will be at the heart of the system”, and this approach (which will also drive GP consortia commissioning) will place key responsibility on Directors of Public Health, based in local authorities but working across health and social care. However, local decision making inherently tends to create or exacerbate variation (ie a “Postcode Lottery”). In February 2010, the Marmot Review highlighted profound inequalities in health outcomes across society and across regions, and the need to address this is said to underpin the White Paper. After the promised removal of the “layers of bureaucracy” between the Secretary of State and the front line, the key challenge will be to reconcile this localism with the need to ensure consistency of provision, and as well as planning on a more strategic level when required, for example to respond to pandemic flu or terrorism.

The public health budget will be ring-fenced, with funding transferred to local authorities by way of a section 31 grant, which will enable the DH to place conditions on how the money will be used, though there will be some flexibility. In reality, the dividing line between health and social care provision is very blurred, and it seems inevitable that some will complain that public health funds are actually being used to compensate for cuts in social care budget. The forthcoming comprehensive review of the funding of adult social care may change everything again.

One strong and possibly controversial theme is the “Public Health Responsibility Deal”. Rather than regulation, this promotes voluntary agreements with businesses (such as food and drink companies) and other partners (such as schools). The details on this, as with many of the proposals, are to follow in Spring 2011. The White Paper also promises many more documents during 2011, dealing with smoking, obesity, mental health and emergency planning, among other things.

The timetable for these proposed changes is designed to follow the changes set out in the NHS White Paper. ‘Shadow allocations’ will be made to local authorities in 2012/2013, with real allocations introduced in 2013/14, in line with the abolition of PCTs. Further details are expected in the NHS Operating Framework, which should be out within the next two weeks.

The DH has launched a consultation on the Public Health White Paper, open until 8 March 2011. It asks five very broad questions, reflecting the lack of detail at this stage. We are considering our response to this consultation, and if you have any comments or would like to contribute to our response we would be delighted to hear from you.

talk to us


picture of Ben Troke
Ben Troke
0115 976 6263
Partner
picture of Christian Webb-Jenkins
Christian Webb-Jenkins
0115 976 6175
Partner
picture of Emily Birkett
Emily Birkett
0121 237 3934
Solicitor

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The content of this bulletin is provided for the purposes of general interest and information. It contains only brief summaries of aspects of the subject matter and does not provide comprehensive statements of the law. It does not constitute legal advice and does not provide a substitute for it.

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