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The duty of NHS Trusts and local authorities to cooperate


16 September 2009


Were Vince Cable’s concerns that the NHS may be “going against” the push towards greater partnership with local government warranted?

Liberal Democrat Treasury Spokesman, Vince Cable, at the Local Government Association Annual Conference earlier this year, commented that:

“The work of PCTs and local authorities overlaps so much, we should be talking about joint working in those cases. I worry that the NHS will go its own merry way as it so often does. They are going against that trend.

I have seen examples recently in South West London of PCTs going for alliances and partnerships that cut across local government boundaries and make it much more difficult to get the co-operation that you need”.

We take a look at the key legislation in the cooperation of the NHS and local authorities and what this means in respect of the services they provide.

The NHS bodies and Local Authorities Partnership Arrangements Regulations 2000

The 2000 regulations set out that Primary Care Trusts (PCTs), NHS Trusts and NHS Foundation Trusts may enter into partnership arrangements with a variety of local authorities (LAs) in relation to any NHS and health related functions that the LA may provide. The LAs that these NHS bodies may enter into partnership arrangements with are:

  • ­A district council
  • ­A county council
  • ­A county borough council
  • ­A London borough council
  • ­The Common Council of the City of London
  • ­The Council of the Isles of Scilly

This is only the case, however, if the arrangements are likely to do both of the following:

  • ­Lead to an improvement in the way in which those functions are exercised
  • ­Fulfil the objectives set out in the health improvement plan of the PCT in whose area the arrangements are to operate

Any partnership arrangement must be written and must specify each of the following:

  • The agreed aims and outcomes of the arrangement
  • The payments to be made by LAs to the NHS bodies (or vice-versa) and how those payments may vary
  • The health-related and NHS functions which are the subject of the arrangement
  • The people and types of service in respect of which the functions referred to in (c) above may be exercised
  • The staff, goods, services or accommodation to be provided by the partners in connection with the arrangement
  • The duration of the arrangement as well as provision for the review or variation or termination of the arrangement
  • The arrangements in place for monitoring the exercise by the NHS bodies of LAs (as the case may be) of the functions referred to in (c) above
  • In the case of the exercise of certain functions, the arrangements in place for determining the services where a user may be charged and for informing users about such charges

The NHS bodies must report to the local authorities - quarterly and annually - on the implementation of the health-related functions which are the subject of the arrangements. Accordingly, this applies in reverse, in the case of NHS functions subject to such arrangements.

The partners may also enter into arrangements for, or in connection with, the establishment and maintenance of a fund (pooled fund arrangements) which is made up of contributions by the partners. From this, payments may be made towards expenditure incurred in the exercise of any NHS or health-related functions. However, it should be noted that a partner which is an NHS Trust may not enter into pooled fund arrangements with a partner that is a LA unless, it obtains the consent of each PCT with which it has an NHS contract for the provision of services for persons in respect of whom the functions which are the subject of the pooled fund arrangements may be exercised.

Therefore, whilst the regulations do not place any obligations on NHS bodies and LAs to work together, they clearly envisage partnership arrangements to improve the way in which the functions of these bodies are delivered.

Historically, these arrangements were known as Section 31 Agreements under the Health Act 1999. The provisions of section 31 have since been replaced by section 75 of the National Health Service Act 2006.

Section 75 of the National Health Service Act 2006

Section 75 goes further, setting out that the Secretary of State may step in and make provisions for NHS bodies (excluding Special Health Authorities) to enter into similar ‘prescribed arrangements’ if it will lead to an improvement in the delivery of their functions.

Essentially, these ‘prescribed arrangements’ are partnering and associated arrangements, allowing the NHS to undertake health-related functions on behalf of a LA and vice-versa in respect of LA functions. The emphasis though, is on working together to create “an improvement in the way in which those functions are exercised”.

Section 106 of the Local Government and Public Involvement in Health Act 2007

This gives the Secretary of State the power to request LAs to prepare and submit to him a proposed ‘local area agreement’ specifying ‘local improvement targets’. These are targets for improvement in the economic, social or environmental wellbeing of the LA’s area. In preparing the draft agreement, the LA is required to consult all appropriate partner authorities that may be relevant to the delivery of the targets and must cooperate with them all to determine the targets to be set in the agreement.

These regulations also impose obligations on the LA’s partner authorities. The regulations require the partner authorities to cooperate with the LA in determining the local area targets that are to be set. They must also have regard to any guidance issued by the Secretary of State.

NHS bodies are specifically included as ‘partner authorities’ who are therefore required to cooperate with LAs in the preparation of the local area agreement.

As well as these overriding duties to cooperate, there are often specific pieces of legislation that set obligations in respect of areas where the NHS and LAs need to work together.

Section 4 of the Childcare Act 2006

As an example, Section 4 of the Childcare Act 2006 places a duty on LAs working with their partners in the NHS and Jobcentre Plus to improve outcomes for all children and to reduce inequalities by providing integrated early years services. They are required to work together so that all aspects of early childhood services are planned together and delivered in an integrated way, maximising access and benefits to young children and their families. Although integration does not rely on co-location of services, this is clearly very helpful.

In conclusion, it is important to recognise the need for all public sector bodies to act reasonably in their decision making. If improvement in the delivery of services could be achieved by closer partnership working between the NHS and a local authority, it may be held to be unreasonable if a decision is made to not put those arrangements in place.

So, is Vince Cable right to be concerned that the NHS may “go its own merry way”? Whilst the legislation may not force the NHS to work with local authorities to improve services, it does go a long way towards this. With the weight of the statutory framework behind it; the power of the Secretary of State to make provision for NHS and LA arrangements; and with the overriding duty to act reasonably in its decision making, it would be a brave NHS body that would “go its own merry way” in the future.

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picture of Chris Emm
Chris Emm
0115 908 4112
Associate
picture of Stewart Gregory
Stewart Gregory
0115 976 6299
Partner
 

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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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