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Our Governance Handbook

  • Correct as of April 2024

1.1    Welcome to the Governance Handbook for Coventry and Warwickshire Integrated Care Board. This is where you can find all of the documents related to the structures, systems and processes we put in place to ensure the proper management of our work.

1.2     As an organisation we are open and accountable to the population we serve and are committed to putting people at the heart of everything we do. You can find out more about our work with people and communities in our Communities Strategy (a link to which can be found in Appendix 3) as well as on our website.

1.3     If you want to be part of our decision making for health and care services then we would be delighted to hear from you and there are many different ways you can get involved. The “Functions and Decisions Map” in section 4 of the Governance Handbook will show you where all of the decisions that we make are made. Our website is the best source of the latest information on what we are currently considering, including all of our board meetings and papers. It also offers lots of ways to get in touch, including how to attend our board meetings, where we welcome questions, places to submit complaints, comments or Freedom of Information requests, and an up to date list of all the current engagement and consultation being undertaken by the Board. You can also find the details of our two Healthwatch organisations and how to speak to them if you need to.

1.4     We hope this handbook is a useful tool to find out more about how we do things, but if you have any questions or queries, please visit our website and we’ll be happy to help.

2.1     The purpose of this document is to bring together a range of corporate statutory documents in one place and is described as the NHS Coventry and Warwickshire Integrated Care Board Governance Handbook (the "Handbook").

2.2     The Handbook is not a legal requirement; however, it supports the ICB’s Constitution and is an approach that will assist the ICB to build a consistent corporate approach and form part of the corporate memory.

2.3     This handbook is updated annually by the Governance Team and published on the ICB’s website. Any changes to the content of the handbook will be reviewed by the Audit Committee and recommended for adoption by the ICB’s Board.

2.4 Patient and Public Engagement

2.4.1  The ICB shall ensure that while discharging its general duties and functions it shall make arrangements to secure public involvement in planning, development and the decision making of the ICB through established mechanisms as outlined in the ICB’s Communities Strategy (Appendix 3).

2.5 Risk Management

2.5.1  Risk is inherent in everything the ICB does – determining priorities, managing projects and even deciding when not to take action. Effective risk management is therefore an essential enabler to allow the ICB to meet its strategic and corporate objectives. It is reliant on the system partners working together with the ICB to ensure there is visibility of risks across the system that may impact on the ICB’s strategic objectives. Individual system partners share information about their risks as part of the collaboration required for the system to work effectively; this does not remove the responsibility that individual statutory bodies have to manage their own risks.

2.5.2   The ICB’s Risk Management Policy identifies the procedures for risk management, encompassing the management of all types of risk to which the ICB may be exposed. The policy is detailed in Appendix 6.

3.1.    Members of the Board  
3.1.1.    Each member of the Board shares responsibility as part of a team to ensure that the ICB exercises its functions effectively, efficiently and economically, complying with the principles of good governance, Nolan standards of behaviour in public life and in accordance with the terms of this constitution. Each brings their unique perspective, informed by their expertise and experience.
3.1.2.    In addition to the information provided below, further information is provided in section 3 of the ICB’s Constitution.

3.2.    Chair of the Board
3.2.1.    The Chair is responsible for:

  • leading the board in setting a vision, strategy and clear objectives for the ICS/ICB in delivering on the four core purposes of the ICS, the triple aim and the body’s regulatory responsibilities.
  • holding the ICS Leader/ICB Chief Executive to account for delivery of the strategy of the ICS/ICB, the plan for the delivery of health services for the population and effective stewardship of public money.
  • working with Local Government partners to establish the Integrated Care Partnership, establishing a strong relationship between the Board and the Partnership, and a dynamic which encourages a strong focus on health and care outcomes for the population.
  • shaping the new ICS Partnership and aligning the work of the ICB, with local government through the ICB.
  • establishing shared strategic priorities within the NHS in partnership with local government to tackle population health challenges and enhance services across health and social care.
  • advocating for and championing diversity, health equality and social justice. Fostering strong partnership arrangements with local government and wider partners to deliver these aims.
  • ensuring the ICS is responsive to people and communities – and that public, patient and carer voices are embedded in all of the ICS’s/ICB’s plans and activities.
  • leading the system through aligning partners in the implementation of the Long Term Plan and the People Plan, overseeing progress against their objectives.
  • overseeing the purposeful arrangements for effective clinical and professional care leadership throughout the ICS.
  • ensuring the NHS plays its part in social and economic development and achieving environmental sustainability, including the Carbon Net Zero commitment.

3.3.    Deputy Chair 
3.3.1.        The Deputy Chair of the Board will undertake the chairmanship and corporate leadership duties of the Chair when the Chair has a conflict of interest or is otherwise unavailable.
3.3.2.    The Deputy Chair will be selected by the Chair from the Non-Executive Members of the Board.

3.4.    Chief Executive Officer 
3.4.1.    The principal duties of the role are as follows: 

  • leading the organisation to meet population health needs, allocating resources to deliver the plan.  
  • working with partner organisations to develop a “one workforce” strategy for effective clinical and professional care leadership across the ICS.
  • leading a system-wide strategy on data and digital, driving joint working on estates, procurement, supply chain and commercial strategies.  
  • developing and delivering the plan that embeds patient voice and stakeholder engagement, acting as a leader for diversity, health inequalities and social justice.
  • ensuring the NHS’ full engagement in the ICB social and economic development, environment sustainability and in addressing the wider determinants of health.
  • ensuring relevant services are in place to deliver the four core purposes of Integrated Care Systems and the triple aim.  Facilitating transformation of services and oversee delivery of improved outcomes for the ICS population.
  • fostering a culture of research, innovation,  learning and continuous improvement to support the delivery of high-quality services.
  • alongside the Chair, leading the system in implementation of the Long-Term Plan and People Plan, overseeing progress against objectives.
  • supporting the delivery of the ICS/ICB objectives and regulatory responsibilities by ensuring effective governance, performance management arrangements and controls are implemented.

3.5.    Chief Finance Officer 
3.5.1.        The Chief Finance Officer is responsible for:

  • developing the funding strategy for the ICS to support the board in achieving the four statutory aims of integrated care systems, including consideration of place-based budgets, and making use of benchmarking to make sure that funds are deployed as effectively as possible.
  • ensure that the ICB meets the financial targets set for it by NHS England and NHS Improvement, including living within the overall revenue and capital allocation, and the administration costs limit. 
  • jointly with other system partners, ensuring that the Integrated Care System (ICS) delivers its financial targets. 
  • supporting the development and delivery of the long-term plan of the ICB. They will ensure this reflects and integrates the strategies of all relevant partner organisations of the ICS, with a particular focus on developing a shared financial and resourcing strategy. 
  • providing financial leadership and influence across the ICS to ensure that opportunities to drive improvements in population outcomes which includes collaborating and providing financial leadership with key partners (across health, care and wider) to break down barriers, drive innovation and achieve agreed deliverables. 
  • alongside ICB colleagues, working to develop digitally enabled transformation (including financial outcome focused transformation) and the clinical/care elements of a sustainable People Plan for the ICS workforce. 


3.6.    Chief Medical Officer 
3.6.1.    The principal duties of the role are as follows:

  • accountability jointly with the Chief Nursing Officer for:

o     all matters relating to the relevant professional colleagues across the clinical and care workforce employed by the ICB.
o    leading on overseeing quality of health services within the ICS including sharing intelligence and working with other key partners and regulators, across and outside of the System, to improve quality of care and outcomes.
o    securing multi-professional clinical and care leadership in delivery of the ICB’s objectives and to form part of the wider network of clinical and care leaders in the region and nationally.

  • to hold an influential executive role and have shared accountability for the development and delivery of the long-term clinical strategy of the ICB, ensuring this reflects and integrates the strategies of all relevant partner organisations within the ICS. 
  • to be accountable for providing high quality clinical and professional leadership of the ICB’s activities and for securing professional clinical and care leadership in delivery of the ICB’s objectives. 
  • to be designated accountable for statutory and non-statutory functions that the ICB will need to perform as agreed with the Chief Executive Officer. 
  • To be responsible for building partnerships and collaborating with provider collaboratives, public health, local government, other partners, and local people to deliver better access, improvements in life outcomes and reductions in health inequity. 
  • as an ICB board member, to ensure that population health management, innovation and research supports continuous improvements in health and well-being, including digitally enabled clinical transformation, and the clinical and care elements of a sustainable People Plan for the ICS workforce.
  • to influence and work collaboratively with key partners as part of the wider System  to create opportunities to make sustainable long-term improvements to population health.  

3.7.    Chief Nursing Officer 
3.7.1.    The principal duties of the role are as follows:

  • accountability jointly with the Chief Medical Officer for:

o    all matters relating to the relevant professional colleagues across the clinical and care workforce employed by the ICB;
o    leading on overseeing quality of health services within the ICS including sharing intelligence and working with other key partners and regulators, across and outside of the System, to improve quality of care and outcomes;
o    securing multi-professional clinical and care leadership in delivery of the ICB’s objectives and to form part of the wider network of clinical and care leaders in the region and nationally;

  • to hold an influential executive role and shared accountability for the development and delivery of the long-term clinical strategy of the ICB, ensuring this reflects and integrates the strategies of all relevant partner organisations within the ICS. 
  • to be accountable for providing high quality clinical and professional leadership of the ICB’s activities and for securing professional clinical and care leadership in delivery of the ICB’s objectives. 
  • to be designated accountable for statutory and non-statutory functions that the ICB will need to perform as agreed with the Chief Executive Officer. 
  • to be responsible for building partnerships and collaborating with provider collaboratives, public health, local government, other partners, and local people to deliver better access, improvements in life outcomes and reductions in health inequity. 
  • as an ICB board member, ensure that population health management, innovation and research support continuous improvements in patient services including digitally enabled clinical and care transformation and the clinical and care elements of a sustainable People Plan for the ICS workforce. 
  • to influence and work collaboratively with key partners as part of the wider System  to create opportunities to make sustainable long-term improvements to population health.  

3.8.    Chief Transformation Officer 
3.8.1.    The principal duties of the role are as follows:

  • lead and oversee the development and implementation of a system Transformation Programme to ensure the agreed outputs are delivered to time and budget in order to support delivery of the four statutory aims of the ICS. This includes managing the system Programme Management Office (PMO) function.
  • lead the development of the ICS capability and capacity to ensure the system can operate as a mature and thriving ICS and deliver the four statutory aims.
  • take executive responsibility for leading the development and delivery of the system Elective Care Recovery Plan (including Cancer and Diagnostic Services), the system UEC Programme Plan and the system Estates Strategy and underpinning Delivery Plan.
  • take executive responsibility for effective delivery of the system Communication and Engagement function.
  • take executive responsibility for the development of the People Agenda, the People Strategy and the system People function on behalf of the ICS.

3.9.    Partner Members 
3.9.1.    Working alongside the Chair, other non-executives, executive directors and other partner members and as equal members of a unitary board, the purpose of these roles is as follows:

  • Taking collective responsibility for developing and implementing the strategy for the ICB that delivers excellent outcomes for the population ensuring that the four statutory aims are delivered: 

o    improve outcomes in population health and healthcare.
o    tackle inequalities in outcomes, experience and access.
o    enhance productivity and value for money. 
o    help the NHS support broader social and economic development.

  • Holding collective responsibility with the other members of the Board to ensure corporate accountability for the performance of the ICB as part of the wider ICS, including developing and maintaining a positive working relationship with the Integrated Care Partnership and system partners. 
  • Working together with other Board members to ensure their behaviours:

o    create the conditions for success.
o    promote open and transparent decision making.
o    constructively and respectfully challenge. 

  • Setting the standards and promoting values based leadership in all interactions with stakeholders, partners and colleagues. Member partners will have an impartial focus, providing an external view of the ICB according to their skills and expertise.

3.10.    Independent Non-Executive Members 
3.10.1.    The principal duties of the role are as follows:

  • Bringing independent and respectful challenge to the plans, aims and priorities of the ICB.
  • Promoting open and transparent decision-making that facilitates consensus aimed to deliver exceptional outcomes for the population.
  • Setting the vision, strategy and clear objectives for the ICB in delivering on the four core purposes of the ICS, the triple aim of improved population health, quality of care and cost-control.
  • Aligning partners in transforming the Long Term Plan and the People Plan into real progress.
  • Promoting dialogue and consensus with local government and broader partners, to ensure effective joint planning and delivery for system working and mutual accountability.
  • Supporting the success of the ICP in establishing shared strategic priorities within the NHS, in partnership with local government, to tackle population health challenges and enhance services across health and social care.
  • Advocating diversity, health equality and social justice to close the gap on health inequalities and achieve the service changes that are needed to improve population health.  
  • Ensuring the ICB is responsive to people and communities and that public, patient and carer voices are embedded in all of the ICB’s plans and activities.
  • Oversight of purposeful arrangements for effective leadership of clinical and professional care throughout the ICB and the ICS.
  • Ensuring the NHS plays its part in social and economic development and achieving environmental sustainability, including the Carbon Net Zero commitment.
  • Providing visible leadership in developing a healthy and inclusive culture for the organisation..
  • In addition to these duties:
  • one Non-Executive Member will also perform the role of the Chair of the Audit Committee, the role of which is to seek assurance that financial reporting and internal control principles are applied, to maintain an appropriate relationship with the auditors, both internal and external, and provide advice to the board about the reliability and robustness of internal control processes. 
  • one Non-Executive Member will also perform the role of the Chair of the Remuneration Committee, which is accountable to the Board for matters relating to remuneration, fees and other allowances (including pension schemes) for employees and other individuals who provide services to the ICB. 
  • one Non-Executive Member will also perform the role of the Lead for inequalities, whose role is to work across the committees and is accountable to the Board to ensure addressing inequalities is central and not peripheral to decisions made by the ICB.
  • There is no delegation of statutory functions

1.    Introduction

1.1    The Individual Funding Request (IFR) Panel is established in accordance with NHS Coventry and Warwickshire Integrated Care Board’s (the ‘ICB’) Constitution Standing Orders, Scheme of Reservation and Delegation, and Standing Financial Instructions.

2.    Purpose

2.1    The IFR Panel makes decisions in respect of funding for individual cases. The IFR Panel will consider the evidence submitted in respect of a particular patient and reach a decision as to whether exceptional clinical circumstances have been demonstrated so as to justify a decision to allocate funding for this patient for the treatment sought, when the treatment is not routinely provided to the group of patients of which this patient is otherwise representative, or at all.

3.    Authority

3.1    The IFR Panel is a formal sub-committee of the ICB’s Board under the scheme of delegation and, as such, has delegated authority from the ICB’s Board to make decisions in respect of funding for individual cases.

3.2    For the avoidance of doubt, in the event of any conflict, the ICB’s Standing Orders, Standing Financial Instructions and the Scheme of Reservation and Delegation will prevail over these terms of reference.

4.    Reporting

4.1    The IFR Panel reports to the Commissioning, Planning and Population Health Committee. Anonymised minutes of each meeting will be provided to the Commissioning Committee, Planning and Population Health  on a bi-monthly basis. In addition the IFR Team will provide a summary of decisions on an annual basis to the Commissioning , Planning and Population Health Committee and will highlight any individual decisions which may have implications for wider ICB commissioning policy.

5.    Membership

5.1    The members of the IFR Panel are appointed by the Commissioning , Planning and Population Health Committee.  

5.2    A record will be made in the minutes of the Commissioning , Planning and Population Health Committee meeting when members are appointed to the IFR Panel and will include the names of the appointees

Members 
5.3    Membership of the IFR Panel will be as follows:

•    1 x Non-Executive member (Chair)
•    1 x Executive Director or Director of the ICB
•    2 Clinicians working in the Coventry and Warwickshire health economy
•    1 x Public Health Representative who holds an honorary contract with the ICB

5.4    The Chair of the IFR Panel will be the Non-Executive Member or their nominated alternate from among the other members of the IFR Panel.  

Attendees at meetings
5.5    Other parties may be invited to attend the IFR Panel meeting to present cases.  

5.6    IFR team members will attend to make a record of the proceedings and to provide general administrative support.

5.7    The IFR Team will be responsible for ensuring attendance of the delegated members. These members will also be available throughout the month to make decisions in respect of any urgent cases.

5.8    No individual who has currently, or has had, clinical involvement with a particular patient will be permitted to sit as an IFR Panel member for that case. The requesting clinician may attend to provide clarification of the evidence submitted. Clinicians attending for this purpose will be excluded from the subsequent IFR Panel discussion of the case. 

5.9    Patients will not be invited to attend the IFR Panel hearing.

6.    Meetings and Quorum

6.1    The Panel will meet as required but generally monthly.

6.2    Cases will be considered at the next available Panel meeting. If further information is required to prepare the case for consideration, this may delay presentation to the IFR Panel until the next or subsequent month.

6.3    In cases where urgent consideration is required, an extraordinary Panel meeting may be convened or another method of rapid discussion, e.g. via email, considered. Such decisions will be tabled at the next monthly IFR Panel and recorded in the minutes.

6.4    Cases will be anonymised before consideration by the Panel.

6.5    The IFR Panel will require the attendance of any 3 members to be quorate, one of which must be a GP.

6.6    If there is not a unanimous decision in a particular case, the Chair of the IFR Panel will have the casting vote after taking account of all the clinical advice.

6.7    The IFR Panel may defer a case where additional information/clarification is required to enable a final decision to be made. The Chair will write to the clinician to detail what is required to allow further discussion of the case. If the additional information is not received within three months from the date of the Chair’s letter to the Clinician then the IFR Panel will reconsider the case and reach a decision based on the information available to it at that time.

6.8    The IFR Team, on behalf of the ICB, will produce letters for signature by the Chair, within five working days of the Panel meeting, to the patient (where this is not contra-indicated by the clinician on the initial pro-forma because direct communication is felt not to be in the patient’s best interests) and to the referring clinician, setting out the IFR Panel’s decision and the reasons for it.

6.9    Patients or clinicians who remain unhappy with an IFR Panel decision may request a review of the process by which the decision was reached.

7.    Secretariat and administration

7.1    The IFR Panel will be provided with a secretariat function via the IFR Team of the ICB.

7.2    Papers will be distributed to members and other attendees at least 3 working days in advance of the meeting.

7.3    Formal minutes will be taken and shall include: 

7.3.1    The names of all members and attendees present at the meeting;

7.3.2    Declarations of interest of members and attendees;

7.3.3    A record of matters discussed and agreed;

7.3.4    Matters arising and issues to be carried forward.

8.    Conduct of the IFR Panel

8.1    Members of, and those attending, the IFR Panel shall behave in accordance with the ICB’s Standing Orders and Standards of Business Conduct Policy. 

8.2    The ICBs Conflicts of Interest Policy will apply and procedures to identify, declare and manage conflicts of interest must be followed at all times. 

9.    Review

9.1    These terms of reference and the effectiveness of the Panel will be reviewed at least annually and earlier if required.  

9.2    All reviews will be logged in the Terms of Reference Review Log which is published in the Governance Handbook.

9.3    Any proposed amendments to the terms of reference will be submitted to the ICB’s Board for approval. 

1.    Introduction

1.1    The Individual Funding Request (IFR) Review Panel is established in accordance with NHS Coventry and Warwickshire Integrated Care Board’s (the ‘ICB’) Constitution Standing Orders, Scheme of Reservation and Delegation, and Standing Financial Instructions.

2.    Purpose

2.1    Where an IFR Panel decision does not support funding for the treatment or therapy, a request to the IFR Review Panel can be made by the individual patient affected by the decision or by a carer, a parent/guardian or a clinician on behalf of that individual. Such a request may only be made on the ground that due process was not followed by the IFR Panel in reaching its original decision.

2.2    The IFR Review Panel’s role is to decide whether the IFR Panel has properly followed its own procedures, has properly considered the evidence presented to it and has come to a reasonable decision based upon that evidence.

3.    Authority

3.1    The IFR Review Panel is a sub-committee of the ICB’s Board and part of the corporate governance process of the ICB. 

3.2    The IFR Review Panel is the final arbiter of the decision in the IFR process.

3.3    For the avoidance of doubt, in the event of any conflict, the ICB’s Standing Orders, Standing Financial Instructions and the Scheme of Reservation and Delegation will prevail over these terms of reference.

4.    Reporting

4.1    The IFR Review Panel reports to the ICB’s Board or Commissioning, Planning and Population Health Committee. Anonymised minutes of each meeting will be provided to the closed session of the ICB’s Board on a bi-monthly basis. In addition the IFR Team will provide a summary of decisions on an annual basis to the ICB’s Board and will highlight any individual decisions which may have implications for wider ICB commissioning policy.

4.2    The Accountable Officer will be responsible for reporting the decision in confidential session to the ICB’s Board.

5.    Membership

•    ICB Accountable Officer
•    ICB Chair
•    Any ICB Executive Officer but with the Chief Delivery and Performance Officer as the preferred choice

6.    Meetings and Quorum

6.1    All three members must be present for the IFR Review Panel to be quorate. The Chair will be agreed by the panel members. 

6.2    The IFR Review Panel cannot include a member of the IFR Panel which initially considered the case under appeal, although they can be in attendance to answer any questions the IFR Review Panel may have about how the request was handled by the IFR Panel. Patients and clinicians will not be invited to attend the IFR Review Panel meetings.

6.3    The IFR Review Panel will meet as and when required, when a request for review is lodged against a decision made by the IFR Panel. 

6.4    The IFR Team, on behalf of the IFR Review Panel will produce letters for signature by the Chair, to the patient/carer/parent/guardian and referring clinician giving details of the Panel’s decision within five working days of the Review Panel meeting. 
 
7.    Secretariat and administration

7.1    The IFR Review Panel will be provided with a secretariat function via the IFR Team of the ICB.

7.2    Papers will be distributed to members and other attendees at least 3 working days in advance of the meeting.

7.3    Formal minutes will be taken and shall include: 

7.3.1    The names of all members and attendees present at the meeting;

7.3.2    Declarations of interest of members and attendees;

7.3.3    A record of matters discussed and agreed; and

7.3.4    Matters arising and issues to be carried forward.


8.    Conduct of the IFR Review Panel

8.1    Members of, and those attending, the IFR Review Panel shall behave in accordance with the ICB’s Standing Orders and Standards of Business Conduct Policy. 

8.2    The ICBs Conflicts of Interest Policy will apply and procedures to identify, declare and manage conflicts of interest must be followed at all times. 

9.    Review

9.1    These terms of reference and the effectiveness of the Review Panel will be reviewed at least annually and earlier if required.  

9.2    All reviews will be logged in the Terms of Reference Review Log which is published in the Governance Handbook.

9.3    Any proposed amendments to the terms of reference will be submitted to the ICB’s Board for approval. 

1. Introduction

1.1 General

1.1.1  These prime financial policies and supporting detailed financial policies shall have effect as if incorporated into the ICB’s constitution.

1.1.2  The prime financial policies are part of the ICB’s control environment for managing the organisation’s financial affairs. They contribute to good corporate governance, internal control and managing risks. They enable sound administration, lessen the risk of irregularities and support commissioning and delivery of effective, efficient and economical services. They also help the Chief Executive Officer and Chief Finance Officer to effectively perform their responsibilities. They should be used in conjunction with the scheme of reservation and delegation found at section 3 of the Governance Handbook.

1.1.3  In support of these prime financial policies, the ICB has prepared more detailed policies, approved by the Board known as detailed financial policies. The ICB refers to these prime and detailed financial policies together as the Integrated Care Board’s financial policies.

1.1.4  These prime financial policies identify the financial responsibilities which apply to everyone working for the ICB or operating on behalf of it. They do not provide detailed procedural advice and should be read in conjunction with the detailed financial policies. The Chief Finance Officer is responsible for recommending for approval all detailed financial policies to the Audit Committee.

1.1.5  A list of the ICB’s detailed financial policies will be published and maintained on the ICB’s website. Alternatively, a paper copy can be requested by contacting the Chief Finance Officer at the ICB’s headquarter address.

1.1.6  Should any difficulties arise regarding the interpretation or application of any of the prime financial policies then the advice of the Chief Finance Officer must be sought before acting. The user of these prime financial policies should also be familiar with and comply with the provisions of the ICB’s constitution, standing orders and scheme of reservation and delegation.

1.1.7  Failure to comply with prime financial policies and standing orders can in certain circumstances be regarded as a disciplinary matter that could result in dismissal.

1.2 Overriding Prime Financial Policies

1.2.1  If, for any reason these prime financial policies are not complied with, full details of the non-compliance and any justification for non-compliance and the circumstances around the non-compliance shall be reported to the next formal meeting of the Board’s Audit Committee for referring action or ratification. All of the ICB’s members and employees have a duty to disclose any non-compliance with these prime financial policies to the Chief Finance Officer as soon as possible.

1.3 Responsibilities and Delegation

1.3.1  The roles and responsibilities of ICB’s members, employees, members of the Board, members of the Board’s committees and sub-committees, members of the ICB’s committee and sub-committee (if any) and persons working on behalf of the ICB are set out in the ICB’s constitution and the Governance Handbook.

1.3.2  The financial decisions delegated by members of the ICB are set out in the ICB’s Constitution.

1.4 Contractors and their Employees

1.4.5  Any contractor or employee of a contractor who is empowered by the ICB to commit the ICB to expenditure or who is authorised to obtain income shall be covered by these instructions. It is the responsibility of the Chief Executive Officer to ensure that such persons are made aware of this.

1.5 Amendment of Prime Financial Policies

1.5.1  To ensure that these prime financial policies remain up-to-date and relevant, the Chief Finance Officer will review them at least annually.

1.5.2  Following consultation with the Chief Executive Officer and scrutiny by the Board’s Audit Committee, the Chief Executive Officer will recommend amendments, as fitting, to the Audit Committee who will endorse any amendments for Board’s approval.

1.5.3  As these prime financial policies are an integral part of the ICB’s constitution, any amendment will not come into force until the ICB applies to NHS England and that application is granted.


2. Internal Control

POLICY – The ICB will put in place a suitable control environment and effective internal controls that provide reasonable assurance of effective and efficient operations, financial stewardship, probity and compliance with laws and policies.

2.1    The Board is required to establish an Audit Committee with terms of reference agreed by the Board (see Appendix 2 of the ICB’s constitution for further information).

2.2    The Chief Executive Officer has overall responsibility for the ICB’s systems of internal control.

2.3    The Chief Finance Officer will ensure that:

  • Financial policies are considered for review and update annually;
  • A system is in place for proper checking and reporting of all breaches of financial policies; and
  • A proper procedure is in place for regular checking of the adequacy and effectiveness of the control environment.

 

3. Audit

POLICY – The ICB will keep an effective and independent internal audit function and fully comply with the requirements of external audit and other statutory reviews.

3.1    The Chief Finance Officer and the ICB’s internal auditor will have direct and unrestricted access to Audit Committee members and the Chair of the Board and the Chief Executive Officer for any significant issues arising from audit work that management cannot resolve, and for all cases of fraud or serious irregularity.

3.2    The Chief Finance Officer and the ICB’s external auditor will have access to the Audit Committee and the Chief Executive Officer to review audit issues as appropriate. All Audit Committee members, the Chair of the Board and the Chief Executive Officer will have direct and unrestricted access to the head of internal audit and external auditors.

3.3    The Chief Finance Officer will ensure that:

  • The ICB has a professional and technically competent internal audit function; and
  • The Board’s Audit Committee approves any changes to the provision or delivery of assurance services to the ICB.

3.4 Role of Internal Audit

3.4.1  Internal Audit shall independently review, appraise and report upon:

  • The extent of compliance with, and the financial effect of, relevant established policies, plans and procedures;
  • The adequacy and application of financial and other related management controls, and risk of management and risk based planning;
  • The suitability of financial and other related management data;
  • The extent to which ICB‘s assets and interests are accounted for and safeguarded from loss of any kind, arising from
  • fraud and other offences,
    • waste, extravagance, inefficient administration;
    • poor value for money or other causes.
  • Internal Audit shall also independently verify the Assurance Framework statements in accordance with guidance from the DH.

3.5 External Audit

3.5.1  The external auditor is appointed and paid for by the ICB. The Audit Committee must ensure a cost-efficient service. If there are any problems relating to the service provided by the external auditor, then these should be raised with the external auditor and referred on to the National Audit Office if the issue cannot be resolved.

4. Fraud and Corruption

POLICY – The ICB requires all staff to always act honestly and with integrity to safeguard the public resources they are responsible for. The ICB will not tolerate any fraud perpetrated against it and will actively chase any loss suffered.

 

4.1    The Board’s Audit Committee will satisfy itself that the ICB has adequate arrangements in place for countering fraud and shall review the outcomes of counter fraud work. It shall also approve the counter fraud work programme.

4.2    The Board’s Audit Committee will ensure that the ICB has arrangements in place to work effectively with NHS Protect.

4.3    The Board shall nominate a suitable person to carry out the duties of the Local Counter Fraud Specialist as specified by the DH Fraud and Corruption Manual.

4.4    The Board shall ensure that its members and, as far as reasonably practicable, the ICB as a whole conduct all business with due consideration of general duties and obligations arising from the Bribery Act 2010.

4.5    The Local Counter Fraud Specialist will provide a written report, at least annually, on counter fraud work within the ICB.

4.6    The Local Counter Fraud Specialist will report to the Chief Finance Officer.

4.7    Security Management:

  • In line with his responsibilities, the Chief Executive Officer will monitor and ensure compliance with Directions issued by the Secretary of State for Health on NHS Security Management.
  • The Board shall nominate a suitable person to carry out the duties of the Local Security Management Specialist (LSMS) as specified by the Secretary of State.
  • The Board shall nominate a Non-Executive Member to oversee the Local Security Management service, who will report to the Board.

5. Expenditure Control

5.1    The ICB is required by statutory provisions to ensure that its expenditure does not exceed the aggregate of allocations from NHS England and any other sums it has received and is legally allowed to spend.

5.2    The Chief Executive Officer has overall executive responsibility for ensuring that the ICB complies with its statutory obligations, including its financial and accounting obligations, and that it exercises its functions effectively, efficiently and economically and in a way which provides good value for money.

5.3    The Chief Finance Officer will:

  • Provide reports in the form required by NHS England;
  • Ensure money drawn from NHS England and is required for approved expenditure only and is drawn down only at the time of need and follows best practice;
  • Be responsible for ensuring that an adequate system of monitoring financial performance is in place to enable the ICB to fulfil its statutory responsibility not to exceed its expenditure limits, as set by direction of NHS England.

6. Allocations

6.1    The ICB’s Chief Finance Officer will:

  • Periodically review the basis and assumptions used by NHS England for distributing allocations and ensure that these are reasonable and realistic and secure the ICB’s entitlement to funds;
  • Prior to the start of each financial year, submit to Board for approval a report showing the total allocations received and their proposed distribution including any sums to be held in reserve; and
  • Regularly update the Board on significant changes to the initial allocation and the uses of such funds.

 

7. Commissioning, Strategy, Budgets, Budgetary Control and Monitoring

POLICY – The ICB will produce and publish an annual commissioning plan that explains how it proposes to discharge its financial duties. The ICB will support this with comprehensive medium term financial plans and annual budgets.

 

7.1    The Chief Executive Officer will compile and submit to the Board an ICB strategy which takes into account financial targets and forecast limits of available resources.

7.2    The Board will approve consultation arrangements for the ICB’s five year plan which sets out how the ICB will discharge its duties as set out in 7.3.8 of the Constitution and the proposed steps it will take to implement the ICP Strategy and Coventry Health and Wellbeing Board and Warwickshire Health and Wellbeing Board’s local health and wellbeing strategies.

7.3    Prior to the start of the financial year the Chief Finance Officer will, on behalf of the Chief Executive Officer, prepare and submit budgets for approval by Board.

7.4    The Chief Finance Officer shall monitor financial performance against budget and plan, periodically review them, and report to the Board. This report should include explanations for variances. These variances must be based on any significant departures from agreed financial plans or budgets.

7.5    The Chief Executive Officer is responsible for ensuring that information relating to the ICB’s accounts or to its income or expenditure, or its use of resources is provided to NHS England as requested.

 

8. Annual Accounts and Reports

POLICY – The ICB will produce and submit to NHS England accounts and reports in accordance with all statutory obligations, relevant accounting standards and accounting best practice in the form and content and at the time required by NHS England.

 

8.1    The Chief Finance Officer will ensure the ICB:

  • Prepares a timetable for producing the annual report and accounts and agrees it with external auditors and the Audit Committee;
  • Prepares the accounts according to the timetable approved by Audit Committee;
  • Ensures delivery against the approved timetable, including obtaining sign off by the Board.
  • Complies with statutory requirements and relevant directions for the publication of an annual report;
  • Considers the external auditor’s management letter and fully address all issues within agreed timescales; and
  • Publishes the external auditor’s management letter on the ICB’s website at and makes it available upon request via the Head of Governance and Corporate Affairs. A copy will also be available for inspection at the ICB’s offices.

 

9. Information Technology

POLICY – The ICB will ensure the accuracy and security of its computerised financial data.

 

9.1    The Chief Finance Officer is responsible for the accuracy and security of the ICB’s computerised financial data and shall:

  • Devise and implement any necessary procedures to ensure adequate (reasonable) protection of the ICB’s data, programs and computer hardware from accidental or intentional disclosure to unauthorised persons, deletion or modification, theft or damage, having due regard for the Data Protection Act 2018;
  • Ensure that adequate (reasonable) controls exist over data entry, processing, storage, transmission and output to ensure security, privacy, accuracy, completeness, and timeliness of the data, as well as the efficient and effective operation of the system;
  • Ensure that adequate controls exist such that the computer operation is separated from development, maintenance and amendment;
  • Ensure that an adequate management (audit) trail exists through the computerised system and that such computer audit reviews as the Chief Finance Officer may consider necessary are being carried out.

9.2    In addition, the Chief Finance Officer shall ensure that new financial systems and amendments to current financial systems are developed in a controlled manner and thoroughly tested prior to implementation. Where this is undertaken by another organisation, assurances of adequacy must be obtained from them prior to implementation.

 

10. Accounting Systems

POLICY – The ICB will run an accounting system that creates management and financial accounts.

 

10.1    The Chief Finance Officer will ensure:

  • The ICB has suitable financial and other software to enable it to comply with these policies and any consolidation requirements of NHS England;
  • Contracts for computer services for financial applications with another health organisation or any other agency shall clearly define the responsibility of all parties for the security, privacy, accuracy, completeness, and timeliness of data during processing, transmission and storage. The contract should also ensure rights of access for audit purposes.

10.2    Where another health organisation or any other agency provides a computer service for financial applications, the Chief Finance Officer shall periodically seek assurances that adequate controls are in operation.

 

11. Bank Accounts

POLICY – The ICB will keep enough liquidity to meet its current commitments.

 

11.1    The Chief Finance Officer will:

  • Review the banking arrangements of the ICB at regular intervals to ensure they are in accordance with Secretary of State directions, best practice and represent best value for money;
  • Manage the ICB’s banking arrangements and advise the ICB on the provision of banking services and operation of accounts;
  • Prepare detailed instructions on the operation of bank accounts.

11.2    The Board shall approve the banking arrangements.

 

12. Income, Fees and Charges and Security of Cash, Cheques and Other Negotiable Instruments

POLICY – the ICB will:

  • operate a sound system for prompt recording, invoicing and collection of all monies due;
  • seek to maximise its potential to raise additional income only to the extent that it does not interfere with the performance of the ICB or its functions;
  • ensure its power to make grants and loans is used to discharge its functions effectively.

 

12.1    The Chief Finance Officer is responsible for:

  • Designing, maintaining and ensuring compliance with systems for the proper recording, invoicing, and collection and coding of all monies due;
  • Establishing and maintaining systems and procedures for the secure handling of cash and other negotiable instruments;
  • Approving and regularly reviewing the level of all fees and charges other than those determined by NHS England or by statute. Independent professional advice on matters of valuation shall be taken as necessary
  • Developing effective arrangements for making grants or loans.

 

13. Tendering and Contracting Procedure

POLICY – The ICB will:

  • Ensure proper competition that is legally compliant within all purchasing to ensure it incurs only budgeted, approved and necessary spending.
  • Seek value for money for all goods and services.
  • Ensure that competitive tenders are invited for:
    • the supply of goods, materials and manufactured articles;
    • the rendering of services including all forms of management consultancy services (other than specialised services sought from or provided by the Department of Health); and
    • the design, construction and maintenance of building and engineering works (including construction and maintenance of grounds and gardens) and for disposals.

 

13.1    The ICB shall ensure that the firms/individuals invited to tender (and where appropriate, quote) are among those on approved lists or where necessary a framework agreement. Where in the opinion of the Chief Finance Officer, it is desirable to seek tenders from firms not on the approved lists, the reason shall be recorded in writing to the ICB’s Audit Committee.

13.2    The Board may only negotiate contracts on behalf of the CB, and the ICB may only enter into contracts, within the statutory framework set up by the 2006 Act, as amended by the 2012 Act. Such contracts shall comply with:

  • The ICB’s standing orders;
  • The Public Contracts Regulation 2006, any successor legislation and any other applicable law; and
  • And take into account as appropriate any applicable NHS England or the Independent Regulator of NHS Foundation Trusts (Monitor) guidance that does not conflict with (b) above.

13.3    In all contracts entered into, the ICB shall endeavour to obtain best value for money. The Chief Executive Officer shall nominate an individual who shall oversee and manage each contract on behalf of the ICB.

 

14. Commissioning

POLICY –Working in partnership with relevant national and local stakeholders, the ICB will commission certain health services to meet the reasonable requirements of the persons for whom it has responsibility.

 

14.1    The ICB will coordinate its work with NHS England, other clinical commissioning groups, local providers of services, local authority, including through Health & Wellbeing Boards, patients and their carers and the voluntary sector and others as appropriate to develop robust commissioning plans.

14.2    The Chief Executive Officer will establish arrangements to ensure that regular reports are provided to the Finance and Performance Committee detailing actual and forecast expenditure and activity for each contract.

14.3    The Chief Finance Officer will maintain a system of financial monitoring to ensure the effective accounting of expenditure under contracts. This should provide a suitable audit trail for all payments made under the contracts whilst maintaining patient confidentiality.

 

15. Risk Management

POLICY – The ICB will put arrangements in place for evaluation and management of its risks.

 

15.1    The Chief Executive Officer shall ensure that the ICB has a programme of assurance management, in accordance with current Department of Health assurance framework requirements, which must be approved and monitored by the Board.

15.2    The programme of risk management shall include:

  • A process for identifying and quantifying risks and potential liabilities;
  • Engendering among all levels of staff a positive attitude towards the control of risk;
  • Management processes to ensure all significant risks and potential liabilities are addressed including effective systems of internal control, cost effective insurance cover, and decisions on the acceptable level of retained risk;
  • Contingency plans to offset the impact of adverse events;
  • Audit arrangements including; internal audit, clinical audit, health and safety review;
  • A clear indication of which risks shall be insured;
  • Arrangements to review the risk management programme.

15.3    The existence, integration and evaluation of the above elements will assist in providing a basis to make a statement on the effectiveness of Internal Control within the Annual Report and Accounts as required by current Department of Health guidance.

15.4    Details of the processes and responsibilities relating to the management of risk and assurance including processes to populate and score risks are set out in the ICB’s Risk Policy and Strategy which is available on the ICB’s website or upon request at the ICB’s headquarters.

 

16. Payroll

POLICY – The ICB will put arrangements in place for an effective payroll service.

 

16.1    The Chief Finance Officer will ensure that the payroll service selected:

  • Is supported by appropriate (i.e. contracted) terms and conditions;
  • Has adequate internal controls and audit review processes;
  • Has a suitable arrangement for the collection of payroll deductions and payment of these to appropriate bodies.

16.2    In addition the Chief Finance Officer shall set out comprehensive procedures for the effective processing of payroll.

 

17. Non-pay Expenditure

POLICY – The ICB will seek to obtain the best value for money goods and services received.

 

17.1    The Board will approve the level of non-pay expenditure on an annual basis. Delegated financial limits for non-pay expenditure will be determined by the Chief Finance Officer and reviewed annually and approved by the Audit Committee.

17.2    The Chief Executive Officer shall set out procedures on the seeking of professional advice regarding the supply of goods and services.

17.3    The Chief Finance Officer will:

  • Advise the Board on the setting of thresholds above which quotations (competitive or otherwise) or formal tenders must be obtained; and, once approved, the thresholds should be incorporated in the scheme of reservation and delegation;
  • Be responsible for the prompt payment of all properly authorised accounts and claims;
  • Be responsible for designing and maintaining a system of verification, recording and payment of all amounts payable.

 

17.4 Joint Finance Arrangements with Local Authorities and Voluntary Bodies.

Payments to local authorities and voluntary organisations made under the powers of Sections 256 and 257 of the NHS Act 2006 shall comply with procedures laid down by the Chief Finance Officer which shall be in accordance with these Acts and the 2000 Directions of the Secretary of State.

 

18. Capital Investment, Fixed Asset Registers and Security of Assets

POLICY – The ICB will put arrangements in place to manage capital investment, maintain an asset register recording fixed assets and put in place polices to secure the safe storage of the ICB’s fixed assets.

 

18.1    The Chief Executive Officer will:

  • Ensure that there is an adequate appraisal and approval process in place for determining capital expenditure priorities and the effect of each proposal upon plans;
  • Be responsible for the management of all stages of capital schemes and for ensuring that schemes are delivered on time and to cost;
  • Ensure that the capital investment is not undertaken without confirmation of purchaser(s) support and the availability of resources to finance all revenue consequences, including capital charges;
  • Be responsible for the maintenance of registers of assets, taking account of the advice of the Chief Finance Officer concerning the form of any register and the method of updating, and arranging for a physical check of assets against the asset register to be conducted once a year.

18.2    The Chief Finance Officer will prepare detailed procedures for the disposals of assets.

 

19. Retention of Records

POLICY – The ICB will put arrangements in place to retain all records in accordance with NHS Code of Practice Records Management 2006 and other relevant notified guidance.

 

19.1    The Chief Executive Officer shall:

  • Be responsible for maintaining all records required to be retained in accordance with NHS Code of Practice Records Management 2006 and other relevant notified guidance;
  • Ensure that arrangements are in place for effective responses to Freedom of Information requests;
  • Publish and maintain a Freedom of Information Publication Scheme.

 

20. Trust Funds and Trustees

POLICY – The ICB will put arrangements in place to provide for the appointment of trustees if the ICB holds property on trust.

 

20.1    The Chief Finance Officer shall ensure that each trust fund which the ICB is responsible for managing is managed appropriately with regard to its purpose and to its requirements.

 

21. Acceptance of Gifts by Staff and Link to Standards of Business Conduct

21.1    The Chief Finance Officer shall ensure that all staff are made aware of ICB policy on acceptance of gifts and other benefits in kind by staff (see Managing Conflicts of Interest Policy, Appendix 6 of the Governance Handbook).

21.2    Details of all hospitality received by staff shall be entered in a register maintained by the Director of Corporate Affairs.

 

22. Commissioning Support Service

22.1    The Chief Finance Officer will be responsible for ensuring a comprehensive Service Level Agreement is in place for services provided by any selected Commissioning Support Service.

22.2    The Chief Finance Officer will endeavour to ensure that the contract for such services represents value for money.

22.3    The Chief Finance Officer will ensure the Board can be assured as to the accuracy and quality of services delivered by any selected Commissioning Support Service.