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Rethink urged on key elements of public health plan

The NHS Confederation today (30 March) praises the Government for prioritising public health in its recent white paper, but has warned that a number of proposals need to be rethought to avoid unintended consequences for the health of the nation.

The NHS Confederation's response to Healthy lives, healthy people, the Government's public health white paper, says that funding is a key concern. While public health funding is to be ring fenced, it is not easy to identify and measure the activity it is spent on.

Member engagement

Our members contributed to the consultation between November 2010 and March 2011 in the following ways: 

  • Forty-five members debated the key challenges and opportunities at a white paper engagement event on 2 February 2011, 68 discussed the reforms at a Service Delivery Organisation network event on public health research on 15 February 2011 and 95 members exchanged views at the public mental health and well-being summit on 8 December 2010.
  • We engaged with 105 of our network members through board meetings, other events, policy seminars, telephone conversations and email.

NHS Confederation response

Read the response in full which includes an executive summary and sets out our views on:

  • making the new public health system work
  • funding and commissioning for public health
  • public mental health and well-being
  • children's public health
  • public health intelligence and evidence
  • outcomes
  • managing the transition
  • public health workforce.


Our members are worried that local authorities may not have enough money to commission and deliver all the public health services for which they are to be responsible.

Most worrying, however, is the Government’s use of a health premium to reward those areas that reduce health inequalities most with extra money each year. Rewarding areas for success is right in principle but, as the plans stand, there is a serious risk the most deprived areas where public health challenges are at their most difficult will lose out.

The consultation response argues that the funding model does not reflect the generational challenges the most deprived areas face. Public health problems can often take decades to make progress on and poorer areas also have a high turnover of population meaning that if funding is going to achieve long-term results it needs to be held steady over a longer period than the policy currently seems to suggest. 

Those areas where it is easiest to reduce health inequalities will almost certainly be able gain disproportionately in comparison with those that have the most deep-seated and long term problems.

When taken into consideration with overall funding mechanisms which will take away funding as public health improves, the health premium, as presented in the white paper, risks being an unhelpful one-size-fits-all approach. It needs to be reformulated so the areas where we know public health money is needed most are not unfairly dealt with.

It is also vital to make sure that, having given responsibility for public health to councils, they need to have strong enough powers to hold the various parts of the system to account. More clarity is needed on how local councils, the NHS Commissioning Board and Public Health England are going to work together because it is unrealistic to expect they will all agree on everything, let alone the best ways to act on their priorities.

Clarification necessary

The NHS Confederation submission goes on to identify a number of other areas in the policy that appear incoherent and need to be clarified.

Sexual health services, children’s vaccinations, the public health workforce including health visitors, and child safeguarding have all either been split up to be commissioned to by different bodies at different levels or, in the case of child safeguarding missed out from the white paper completely.

It would be better, and reflect the spirit of the Government’s policy more accurately, if these important areas were coordinated in one place and then enacted through different bodies with clear accountability lines rather than fragmented across the system.

However, the key immediate challenge identified by those currently running the public health system is the transition to the new system. It is vital that the Government takes steps to ensure expertise is not lost from the system and the movement from one system to another is as smooth as possible.


NHS Confederation deputy policy director Jo Webber said: “We support the Government’s plans to bring public health together in local authorities as it offers genuine potential to coordinate policy across a wider range of public services such as school and housing. 

“But while the intentions in the white paper are the right ones, there are areas where it needs a serious rethink to prevent the policy from becoming self-defeating." 


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