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FoI Request for Hampshire/IoW STP draft refused by NHS Improvement

Last week, NHS Improvement rejected a Freedom of Information request to see a copy of the Hampshire and Isle of Wight draft STP plan. It did so by relying on the FOIA exemption that allows public bodies to withhold a document if it will eventually be published at a later date. In a reasoned statement, Penny Emerit of NHS Improvement explained that:

  • STP plans “are to be published shortly in the coming months
  • They don’t want to pre-empt arrangements for “subsequent engagement or consultation”
  • There will be a “wider communications plan to support release of STPs” so they do not want to “disrupt” that plan


In the Institute’s view, we understand that a number of STPs have already made their plans public; we assume the FOIA request went to NHS Improvement because Hampshire had refused to share its document. They have done so, we think in order to enable better engagement with key stakeholders, for it is difficult to see how meaningful dialogue has been possible in recent weeks without at least some of the papers being shared with local authorities, NHS providers, Healthwatch and Community Groups.

Now at least we have clarification that the NHS is determined to refuse publication unless local Managers have already agreed. We also know that publication may be delayed in some places, though David Mowat MP, Parliamentary Under-Secretary of State at the Department of Health said in the debate on 14th September that “When the STPs come back in October after being signed off, they will be consulted on …” That had looked to us to be a pretty clear-cut commitment.

Readers may find it useful to read an article by Daniel Reynolds of NHS Providers, with a very balanced review of the STP process

It is entitled “Moving beyond consultation to genuine public engagement is key to STPs” and is available here.

In the article he asserts that many organisations need to be involved in developing these plans but concludes that “in many STPs, this appears to have been patchy and sporadic at best so far.” 

Here in the Consultation Institute, we agree with this, and that is why we have now announced a series of options to help individual STP footprints.

We can offer:-

  • An STP engagement assessment

Institute Associates will examine the engagement and/or consultation undertaken by the STP project Leads so far, and form an independent view of the extent and quality of those activities. It will consider all key documents (The Guidance is very strong on there being a demonstrable audit trail), meet the key staff, assemble data on individual stakeholder interfaces and examine current plans for on-going dialogue on the STP. Our conclusions and recommendations will be delivered to the client in an agreed manner, and we expect most assignments to require 3 or 4 days’ effort, with detailed costs subject to discussion

  • Advice and Guidance re STP engagement

Where no assessment is required, the Institute will make Associates available on usual (Framework agreement) terms to provide a range of NHS/Local Authority Advice & Guidance, and drawing from experience in all the various environments where we operate. We will offer this on a minimum assignment of three days work, on larger plans this could be as much as ten days work. Again, detailed costs will be subject to discussion

  • Executive Briefings

The STP process involves Managers some of whom have relatively less experience or know-how of the relevant engagement/consultation obligations. Many of the key engagement Leads struggle to convince such people of the importance of the engagement agenda. The Institute now has a track record of running tailored sessions for CCGs and providers. Fees will depend upon who delivers and the extent of the agenda, but is typically less than £2.5k

Anyone interested can call the Institute on 01767 318350 or email

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