The LGA recognises the ambition to reform the National Health Service (NHS) and improve how services are delivered.
Key messages
- The LGA recognises the ambition to reform the National Health Service (NHS) and improve how services are delivered. The requirement for Integrated Care Boards (ICBs) and partners to develop plans at neighbourhood level rightly reflects the importance of locally tailored approaches. Local government will be critical to this, bringing a detailed understanding of communities and the ability to convene partners to support joined-up, place-based care. As the Bill is implemented it will be important to ensure alignment with existing statutory arrangements and planning processes across health and local government including the role of Health and Wellbeing Boards (HWBs), to support effective joint working and avoid unnecessary complexity.
- Strong integration depends on effective local leadership and collaboration. Removing mandatory local authority representation from ICBs is a step backwards from a joined-up and localised approach, given councils are at the forefront of neighbourhood and place-based delivery. This also risks weakening the link between system decision-making and local need, particularly as ICBs cover larger populations, and local government should continue to play a formal role in ICB decision-making.
- Local Healthwatch plays an important role in ensuring the views of patients and communities are heard. We are concerned that removal without a clear alternative, or splitting responsibilities between councils and Integrated Care Boards, risks fragmentation, duplication and a gap in statutory patient voice and public accountability. It is critical that there is an effective and robust plan to retain the local functions of Healthwatch in another statutory body.
- The LGA supports the introduction of a Single Patient Record (SPR) as a foundation for integrated, person‑centred care. To deliver its full value, the SPR must be interoperable across the whole health and care system, including social care. In time there could also be a valuable opportunity for it to include the wider determinants of health such as housing and benefits, supporting a shift towards a Single Person Record. Progress is currently limited by inconsistent data standards and fragmented information governance, which must be addressed through a unified, system‑wide approach focused on linking existing datasets. Development of the SPR should be co‑produced with local government, the NHS and wider partners, drawing on learning from successful regional models to ensure solutions are practical, deliverable and sustainable.
- Digital transformation in health and care must be delivered alongside a clear and sustained commitment to digital inclusion. Councils play a central role in supporting residents to access services through trusted, place‑based support, including face‑to‑face provision and community partnerships. As reforms such as the Single Patient Record are implemented, it will be essential that digital access complements, rather than replaces, non‑digital routes, to avoid deepening health inequalities for people who lack digital skills, confidence, devices or connectivity.
Integrated Care Boards (ICBs)
Background
ICBs were established to support joined-up NHS and local government decision-making at system level, with local authorities holding a formal role in governance. This has helped align NHS commissioning with local priorities, including adult social care, public health and wider determinants of health.
While the model has been complex and influence has varied in practice, it has provided a direct route for local democratic input into NHS decision-making.
The Bill removes the requirement for local authority representation on ICBs, reflecting a shift toward simpler governance, greater national accountability, and system-level decision-making. This reduces formal local influence and creates a tension whereby councils are expected to deliver integrated care, while having fewer levers to shape system decisions.
LGA view
Removing the requirement for local authority representation on ICBs is a backwards step. It risks weakening the partnership approach that has been developing between the NHS and local government and narrowing the range of perspectives that inform decisions.
ICBs were designed to support shared leadership across health and local government. Taking away the only guaranteed route for council involvement reduces formal local influence and shifts the balance towards a more centralised model of decision making.
Why local authority representation is important
Local authorities bring a distinct contribution. They are democratically accountable and responsible for adult social care, public health and services such as housing that shape people’s health day to day. Their involvement helps ensure that decisions are grounded in local priorities and connected to the wider factors that influence outcomes, not just healthcare activity.
They also provide insight at neighbourhood level. As ICBs operate across large geographies, councils play an important role in ensuring that system decisions reflect differences between places and communities, rather than applying a single approach across diverse populations.
More broadly, local government helps bring together partners across the NHS, voluntary and community sector, business and education. This convening role is central to delivering integrated, place‑based models of care.
Benefits that will be lost without local authority representation
While prevention is a shared priority across the NHS and local government, many of the services and levers needed to deliver it sit with councils. Without local authority representation, there is a risk that those levers are less directly connected to commissioning decisions, making prevention harder to prioritise and implement consistently.
Councils bring insight on inequalities, community need and how services work together locally. This helps balance system priorities and supports a shift towards earlier intervention and prevention.
There is also a loss of democratic accountability. The current requirement provides a consistent route for locally elected representatives to shape NHS commissioning decisions either directly, or through senior council officers. Removing it creates a risk that local involvement becomes more variable over time and less embedded in system governance.
At the same time, councils are expected to play a central role in delivering neighbourhood health services and integrated care. This creates a tension where local government retains delivery responsibilities, but with fewer formal levers to influence system level decisions.
It also risks weakening the conditions needed for effective place‑based working. Experience shows that successful integration depends on strong local partnerships and shared system leadership. Without a clear and consistent local government role at system level, there is a greater risk that progress on neighbourhood working becomes uneven and harder to sustain.
More broadly, if local government is not treated as an equal partner in shaping and delivering system priorities, there is a risk that reforms do not fully reflect local context or capability. This could limit the overall impact of national ambitions around prevention, integration and reducing inequalities.
Case studies
There are clear examples where joint working between local authorities and ICBs has improved outcomes and strengthened decision making:
- In Cheshire and Merseyside, the ICB and local authorities have worked together on a Marmot‑based approach to tackling health inequalities. By aligning action on housing, employment and community support with NHS services, the partnership has supported earlier intervention and more targeted support for deprived communities. This has contributed to a clearer system focus on reducing health inequalities and addressing the root causes of ill health, rather than responding only once need escalates.
- In Leicester, Leicestershire and Rutland, collaboration between councils, the NHS and local partners has enabled the development of community‑based infant feeding services, including access to specialist clinical support outside hospital settings. This has improved access for families, reduced the need for hospital referrals, and supported better early‑life health outcomes by intervening earlier and closer to home.
- In Leicestershire, community assessment days bring together health, care and wider local services to assess and support people in a single setting. This has helped people receive faster, more coordinated support, reducing delays between services, avoiding duplication, and in some cases preventing escalation to more intensive or crisis care.
- In Tower Hamlets and Lewisham, joint work between councils and NHS partners on health inequalities and community‑led prevention has helped target services more effectively towards underserved groups. By drawing on local insight and community networks, these approaches have improved engagement with services and supported better uptake of preventative support, particularly in communities that have traditionally been harder to reach.
- In St Helens, long‑standing partnership between the council and health partners has supported work to improve wellbeing in marginalised communities. This has helped reduce inequalities in access to support, strengthen community based prevention, and build more sustainable, locally tailored responses to complex health and social challenges.
Taken together, these examples show that local authority involvement leads to more coordinated services, earlier intervention, improved access, and a stronger focus on reducing inequalities. These are all central to improving health outcomes and managing demand across the system.
Strategic mayoral authority representation
Replacing local authority representation with strategic mayoral authority representation is not a direct substitute. The two roles operate at different levels and bring different types of insight.
Strategic authorities typically operate across populations of 1.5 million or more, while ICBs cover populations ranging from around 500,000 to 3.5 million. By contrast, Health and Wellbeing Boards (HWBs), rooted in local authorities, generally serve populations of around 250,000–500,000 and are closely connected to neighbourhood footprints of approximately 30,000–50,000 people. HWBs therefore provide an important link between regional and system-level decision-making and the realities of local communities, bringing place-based intelligence and democratic accountability that cannot be replicated solely through representation at strategic authority level.
Local authorities provide detailed, place-based knowledge of communities and services. They are responsible for delivery of adult social care, public health and housing, and are closely connected to local partners. This allows them to bring practical insight into how services operate on the ground and how different parts of the system interact.
Strategic mayoral authorities operate at a broader regional level. They play an important role in setting strategic direction, but they are further removed from day‑to‑day service delivery and the operational detail of how health, care and local services work together in specific places.
These roles are complementary. Evidence shows that effective integration depends on strong collaboration and shared leadership across partners, supported by a clear understanding of local needs and services. Removing the guaranteed local authority voice risks weakening that connection and reducing alignment with local communities and the wider determinants of health.
It is also not the case that every area will have a strategic mayoral authority. This means the proposed model would apply unevenly across the country, with some systems benefiting, while others would not. In contrast, the current requirement for local authority representation provides a consistent baseline for local input into decision making across all areas. This risks creating greater variation in how local government is involved in system leadership at a time when consistency of partnership and shared decision making is important to delivering national ambitions around integration and prevention.
As a result, mayoral representation cannot fully replicate the function of local authorities in ensuring that decisions are informed by detailed local context and delivery considerations.
There is also a growing mismatch between NHS, local government and strategic authority footprints. In some areas, Integrated Care Boards are clustered with systems that do not align to emerging mayoral authority geographies or proposed local government reorganisation arrangements. For example, areas within the same strategic authority may sit within different NHS clusters and planning arrangements. This risks creating confusion around accountability, strategic planning and service integration, particularly where neighbourhood health planning is expected to operate across place, system and regional levels simultaneously. Greater clarity is needed on how NHS footprints, neighbourhoods, ICBs, strategic authorities and future local government structures will align in practice.
Changes in the system that will be necessary
As changes are introduced, it will be essential to maintain clear roles, responsibilities and accountabilities, particularly in ensuring that Neighbourhood Health Plans carry forward the core functions currently delivered through Joint Strategic Needs Assessments and Health and Wellbeing Strategies. These arrangements provide a shared, evidence‑based understanding of local need and a broad focus on the wider determinants of health.
There would also need to be sufficient resourcing and capacity within local government, given the expectation that councils will play a central role in delivering neighbourhood health services and integrated care. Without this, responsibilities may increase without the ability to influence or deliver effectively.
Finally, implementation would need to maintain a genuine partnership approach, with local government treated as an equal partner in shaping and delivering system priorities. Evidence shows that integration is most effective where system leaders invest in collaboration and shared vision, rather than relying solely on formal structures.
Neighbourhood Health Plans
Background
HWBs provide strategic leadership at place level through Joint Strategic Needs Assessments and Joint Local Health and Wellbeing Strategies, helping align NHS and local government priorities.
The Bill introduces Neighbourhood Health Plans as a new joint planning mechanism, but does not clearly define how these relate to existing strategies. This creates a risk of duplication, confusion, or the gradual erosion of HWB-led strategies
While neighbourhood planning presents a clear opportunity to strengthen local integration and delivery, there is a risk that plans become more operational and NHS-led, weakening the strategic role of councils and reducing focus on the wider determinants of health.
LGA view
The move toward Neighbourhood Health Plans is a positive step in principle. The ambition to organise care around neighbourhoods, shift towards prevention, and improve coordination across services is long‑standing and strongly aligned with local government priorities
Neighbourhood working offers a clear opportunity to bring services closer to people, support earlier intervention, and better reflect the realities of how people experience health and care. Councils are central to this, given their role in convening partners and addressing the wider determinants of health.
Councils have long delivered integrated, place‑based services across adult social care, public health, housing and children’s services, often alongside NHS and voluntary sector partners. These approaches are typically rooted in community insight and local relationships, and have developed organically over time.
Neighbourhood Health Plans represent a positive opportunity to strengthen integration, prevention and care closer to home, but to realise this fully and build on existing learning, it will be essential that councils are at the centre of shaping what neighbourhood health looks like in practice, ensuring it reflects local priorities, community insight and the full range of factors that influence health and wellbeing.
Their success will depend on whether they:
- Align clearly with existing strategies and avoid duplication.
- Embed a strong and explicit role for local government.
- Reflect the full breadth of services and wider determinants of health.
- Build on established place‑based and neighbourhood working.
How Neighbourhood Health Plans should be developed
Neighbourhood Health Plans should be developed through genuine partnership between the NHS, local government and wider partners, with a clear emphasis on co‑production rather than consultation.
They should be grounded in local evidence and shaped by existing place‑based arrangements, rather than applying a single national model. There is no one definition of a neighbourhood, so footprints should be locally determined and reflect how communities and services actually operate.
Development should also build on established planning frameworks and governance structures, particularly Health and Wellbeing Boards, to ensure continuity and alignment with existing strategies.
Early and sustained engagement will be critical. Tight timelines and late involvement of local partners risk limiting the quality of plans and weakening shared ownership.
Who should be involved in their development?
Neighbourhood Health Plans should involve a broad set of partners, reflecting the range of services and influences on health outcomes.
This includes:
- Local authorities, across adult social care, public health, housing and children’s services
- NHS partners, including ICBs, providers and primary care
- The voluntary, community and social enterprise sector
- Wider local partners such as education, employment and community organisations
Local government has a central role in convening these partners and ensuring plans reflect community insight and local priorities.
Involvement should also extend to residents and people with lived experience, ensuring plans are shaped by how services are actually used and experienced.
Accountability mechanisms that are required
Health and Wellbeing Boards provide an important foundation, offering a democratically accountable forum to oversee priorities and align partners.
Accountability mechanisms also need to maintain a strong and independent route for patient and public voice. Local Healthwatch has played a key role in providing this, acting as an independent source of insight and challenge across health and social care, and supporting local accountability and service improvement.
The proposed abolition of Local Healthwatch creates a risk that this independent voice is lost or fragmented, particularly if responsibility for gathering and responding to feedback sits within the same organisations delivering services.
Accountability mechanisms therefore need to ensure that local voice, insight and challenge remain embedded and independent, alongside maintaining a strong role for local government and democratic oversight as new arrangements are introduced.
Who must be consulted
The Bill does not set out clear expectations on who should be involved in developing Neighbourhood Health Plans. This is particularly important in the context of wider changes. The removal of Healthwatch means the system loses an established, independent route for patient and public voice. That creates a gap in how insight and challenge are brought into planning.
At the same time, neighbourhood health depends on a broad range of partners, including local government, NHS organisations, voluntary and community groups, and local people themselves. Without clearer expectations, there is a risk that plans are developed without meaningful input from those who deliver and use services at a local level.
What plans must contain
There is also no clear steer in the Bill on what Neighbourhood Health Plans should cover.
This matters because there is a risk that plans focus primarily on NHS services, rather than reflecting the wider set of factors that shape health outcomes. Prevention, public health, housing and community support are all central to improving health, but may not be consistently reflected unless this is made explicit.
Without clearer scope, it is uncertain whether plans will support the intended shift towards prevention and community‑based care, or reinforce a more service‑led approach.
Neighbourhood boundaries and care pathways should reflect how residents actually access services, rather than simply mirroring organisational boundaries. In many parts of the country, residents routinely access primary, community and secondary care across ICB boundaries. Without greater national clarity, there is a risk that neighbourhood arrangements create inconsistency in access, confusion for residents and barriers to integrated care. Clear guidance should be provided on how referral pathways, neighbourhood working and preventative services will operate where patient flows cross organisational boundaries.
How delivery is enforced and overseen
The Bill provides limited clarity on how Neighbourhood Health Plans will be overseen or how delivery will be held to account.
This sits alongside wider changes that weaken existing accountability mechanisms. These include the removal of Healthwatch, the abolition of system‑level partnership structures, and the loss of some of the statutory plans that have historically been used to scrutinise NHS decision‑making.
Taken together, this raises a broader issue: Neighbourhood Health Plans are being introduced at the same time as parts of the system that support local oversight and scrutiny are being reduced. This risks leaving plans without a clear or robust accountability framework in practice.
Healthwatch
Background
Healthwatch provides an independent, statutory patient and public voice across health and social care, commissioned locally by councils and embedded in key governance structures such as Health and Wellbeing Boards and scrutiny. It plays a critical role in gathering resident experience, supporting local accountability and informing service improvement.
While effectiveness has varied across the country, Healthwatch has provided a unique independent source of insight across both health and social care.
The Bill abolishes Healthwatch without setting out a clear independent replacement, with patient feedback functions expected to shift into NHS bodies and providers. This raises particular concerns at local level, including the loss of independent challenge, fragmentation of patient voice, and reduced support for local accountability mechanisms. There may be scope to reform national arrangements, but the implications for local systems are more significant.
LGA view
We urge Government to retain a statutory independent local patient voice function and work with councils to develop a clear, workable model for patient and public voice that ensures accountability and independence across health and social care.
By removing the current system for patient and public voice through disbanding Healthwatch, and without setting out a clear independent replacement, we believe this is a significant step back from the accountability framework established following the Francis Report. Without an independent, locally rooted voice to challenge and represent communities, there is a risk of duplication and gaps in accountability. It could also create confusion and frustration for people who, if drawing on both health and care, will need to approach two different parts of the system to share their views.
Under the proposals, NHS bodies and adult social care providers would gather and act on feedback about their own services. Splitting responsibilities across multiple organisations could create a fragmented system, at a time when there is focus on improving integration across health and social care services. The LGA believes a fragmented approach could widen the gap in parity of esteem between health and social care.
Urgent clarity is needed on how funding and statutory duties for patient and public voice will be distributed in the future. This includes how local patient voice will be represented within Health and Wellbeing Boards and Safeguarding Adults Boards, where Healthwatch currently has an important statutory role.
Single Patient Record (SPR)
Background
The Bill supports the development of a SPR to improve integration and coordination of care. This aligns with LGA priorities around person-centred and preventative care.
However, there are risks around scope, access and governance, particularly if the model is defined too narrowly around NHS data. Its success will depend on full inclusion of social care and wider determinants of health, alongside consistent standards and close collaboration with local government.
LGA view
The SPR, as set out in the Health Bill, is a positive step toward addressing long-standing fragmentation in how information is shared across health and care services. The ambition for data to follow the patient and support safer, more joined-up care is widely supported and aligns with existing local practice, where shared care records are already demonstrating tangible benefits.
There is also a strong base of existing learning to inform national progress. Regional models such as the London Care Record and Connecting Care demonstrate that effective data sharing is achievable when it is grounded in clear use cases, strong governance, and partnership working across sectors. Additional practical learning is available through initiatives such as the Shared Care Record Local Government Network.
However, these examples also highlight important considerations for how the SPR is designed and implemented. Past attempts to create national care records have faltered where they were overly broad in scope, lacked clarity about their intended use and did not provide sufficient investment across all parts of the system. Avoiding these pitfalls will require the SPR to be co-produced with a wide range of stakeholders, including people who draw on services, the NHS, local and central government, providers, and the voluntary and community sector.
The evidence also shows that these systems are not single, centralised records, but mechanisms for making existing data visible across systems when needed. This reinforces that value lies in information flow and practical use cases, not simply creating a single dataset. Their success depends heavily on local governance, trust, and agreed standards, rather than technology alone, and they work best where they support practical workflows, such as care coordination, discharge planning and risk management.
There are broader concerns about delivery and framing:
- The key issue is not simply the absence of a shared record, but how information is used to support service coordination and redesigned pathways.
- There is a risk the SPR is implemented in an NHS-centric way, with social care and wider local government insufficiently reflected.
- Barriers to effective data sharing include governance, trust and culture, not just technology alone.
- Without clear expectations on standards, ownership, and portability, there is a risk of reinforcing fragmentation or supplier lock-in.
- A shared record will not improve outcomes unless accompanied by service redesign and workforce change.
- Residents will need to be made aware of any proposed SPR system within their regions, with better user journeys at the centre of any project.
Overall, the SPR has clear potential, but should be understood as an enabling component, not a standalone solution. Drawing on the experience of London and the South West, its success will depend on whether it supports neighbourhood-level working, practical use cases, prevention, and whole-place integration, underpinned by strong partnerships and co-production across the system.
Barriers preventing better data sharing between health and social care services
The barriers to effective data sharing are well understood and are a combination of factors, with non-technical barriers being most significant:
- Governance and legal: uncertainty around consent, data ownership, responsibilities, and lawful sharing.
- Cultural: differing organisational risk aversion and differing norms between NHS and local government.
- Operational: fragmented provider markets in social care, variable digital maturity, and limited capacity.
- Technical: interoperability challenges, inconsistent standards, and data quality issues.
Evidence consistently shows that governance, leadership, and implementation challenges are the primary obstacles, rather than a lack of technology.
The Bill helps address the legal framework, but does not fully tackle:
- The complexity of governance across sectors.
- Cultural and behavioural barriers.
- Fragmentation in the social care provider market.
- Local delivery and implementation capacity.
To strengthen the impact of the Bill, the following would be beneficial:
- Clearer national standards and justifications for data sharing and interoperability.
- Explicit recognition of social care and local government as co-equal partners.
- Model information governance frameworks and agreements.
- Stronger requirements on data portability and supplier interoperability.
- Investment in local implementation capability and provider support.
- A focus on practical use cases (e.g. care coordination, prevention) rather than abstract data-sharing ambition.
Wider determinants of health
A shift is needed from thinking about a “patient” to thinking about a “person.” This means recognising that a meaningful SPR should also reflect key wider determinants of health, such as housing, employment and benefits, education, environment and social support – which heavily influence health and wellbeing.
This means in practice shifting from a Single Patient Record to a Single Person Record, recognising the broader set of needs and circumstances that influence someone’s health and wellbeing.
There is a strong case for extending data sharing beyond health and social care over time. However, this should be approached carefully and pragmatically:
- The immediate priority should be to ensure health and social care data sharing works effectively in practice.
- Expansion should be use-case driven, focused on clear prevention and neighbourhood outcomes.
- Over time, systems should evolve toward whole-place data integration, rather than a single centralised record.
- Data approaches should support both individual care and wider household or community-level understanding.
There is also an important question of sequencing:
- Expanding too quickly risks overcomplicating delivery and undermining trust
- Expanding too slowly risks missing opportunities to address prevention and wider determinants
Unpaid carers
The development of the SPR should also consider the needs for unpaid carers. Information about unpaid carers is held in different parts of the local care and health system but there are no mechanisms for this data to be shared in any consistent way so that carers can be identified early and offered seamless support which enables them to continue caring and look after their wellbeing. If we are to improve outcomes for unpaid carers, and intervene early to prevent carer breakdown, then we need to tackle the barriers to sharing this information.
If we are to improve outcomes for unpaid carers, and intervene early to prevent carer breakdown, then we need to tackle the organisational and cultural barriers to sharing this information. Carers have constant battles with professionals in health and social care services to be recognised as their loved one’s carer and are frustrated by the bureaucracy and repetition involved in getting even a little bit of help. As an example, registering as a carer with a GP is far from a passport to additional support and consideration that most in our focus groups hoped for.
Contact
Arian Nemati, Public Affairs and Campaigns Adviser
Email: [email protected]