Scott Parker is a Senior Manager with Attain. He has worked both in industry and the NHS in a range of commercial roles. Scott’s most recent assignments in Attain have been supporting a range of CCGs and providers with planning and compliance with the Integrated Support and Assurance Process (ISAP), developing business cases to underpin new models of care, responding to tenders and assessing different options around developing an Accountable Care Organisation. Before joining Attain Scott was Commercial Manager at North Somerset Community Partnership, the community health provider in North Somerset. He was executive lead for commercial development, strategic initiatives (new models of care, STP) and the development of meaningful partnerships across the public, voluntary and private sector.
So, what is ISAP and when does it apply?
The Integrated Support and Assurance Process (ISAP) was introduced by NHS England and NHS Improvement late in 2016. The process is designed to provide assurance and support to commissioners who are developing a strategy which involves the procurement of a complex or novel contract through to contract award, and the onward mobilisation of services. The definition of what is a complex or novel contract is potentially open to interpretation but if you are working on the development of a new model of care involving integration across health and social care, a multispeciality community provider (MCP), primary and acute care systems (PACS) or an accountable care network, it is highly likely that ISAP will apply. All these models and approaches are likely to involve the development of risk sharing arrangements, use novel or new approaches to the calculation of the contract value or involve the creation of new legal entities or new organisational forms. In essence, there is an increased level of risk with novel developments and ISAP is designed to support commissioners to reduce and manage the risk. It should therefore be welcomed and seen as an opportunity to test out new approaches and ensure they meet the needs of people and support the delivery of the local Sustainability and Transformation Plans (STP).
The ISAP process
The ISAP process is described in detail in key documentation, found on the NHS England website. As an overview, the process covers four stages / three checkpoints. Each checkpoint requires the preparation of a written submission, an assurance meeting and potentially follow up activity. At each of the four stages (during strategy development, pre-procurement, pre-mobilisation / contract signing and pre-service commencement) the novel contracting process will be assessed against the seven key lines of enquiry (KLOEs) with the initial emphasis on commissioners switching to providers as the process progresses. It is worth highlighting that NHS Improvement’s transaction review is likely to equally apply to NHS trusts as well as NHS foundation trusts at checkpoints 2 and 3.
It is envisaged that the total ISAP will run over a six-month period, but for this to be achievable, commissioners need to ensure they are ISAP ready.
Attain can support your organisation to develop your novel contracting process and to navigate ISAP
Being ISAP ready
Attain advises organisations developing a complex contract to consider the needs of ISAP in advance. Once the process is entered any delays due to failed assurance could negatively impact on the procurement and contracting timelines. Where commissioners are running novel processes in collaboration with a range of partner organisations, this kind of delay could have a significant impact on momentum and confidence.
It is advisable for commissioners to critically review their progress prior to formally engaging in ISAP; some suggestions to focus on are:
- Case for change and strategic context. Is the case for change compelling, well evidenced and fully documented? For example, have the appropriate business cases been produced? Are you able to evidence that proposed changes are what the public wants but also delivers long-term system sustainability? What are the clear clinical benefits? If you are considering a new system of delivery, can you evidence the options considered and the rationale for the final recommendation?
- Stakeholder agreement. If there is a joint process, have all organisations received and signed-off the proposals at the appropriate level? A common situation may be an ambition around integrated health and social care. Under this circumstance formal agreement around long term funding and in-scope services would be desirable, as well as the development of a joint commissioning approach.
- Procurement process. Has the procurement process been well developed, with all documentation drafted and appropriately reviewed by commercial and legal experts? A key consideration will need to be how does the proposed process enable the delivery of the novel contract? If agreements on risk share, integration and partnership are required then providers are going to need time to work through the implications. Through working with clients Attain understands that this can be complex and often needs external support to navigate some of the challenging areas around ownership, governance, contractual agreement and finance (all areas commissioners are likely to want assurance on during the procurement process, so it is ill-advised to rush and ensure providers are able to commit to lasting agreements).
- Capacity and capability. Is the right team in place with the right skills and with sufficient dedicated time to deliver the novel contract through pre-procurement to mobilisation?
- Has the draft contract been produced, setting out key novel approaches such as how an outcomes framework will contribute to provider income?
- Contingency plans. You need to be aware that when trying new approaches that things don’t always go to plan, so you need to understand what the contingency plans are for managing a failed process and possible alteration of plans post-public consultation.