Update on NHS Oversight Framework 2025/26

Agenda item: 10 (Public session)
Report by: Glen Burley: Financial Reset and Accountability Director
Paper type: For information

Executive summary and action required

The new NHS Oversight Framework 2025/26 was issued on 26 June 2025 following a public consultation in May. The framework was approved for release by the Chair and Chief Executive under the delegated authority of the Board as agreed on 20 June, when the Board reviewed the approach and oversight metrics.

This paper provides an overview of the consultation responses and a summary of the new framework.  It is for information only; no action is required.

Issue and context

1. The new NHS Oversight Framework 2025/26 was published on 26 June 2025 and describes a consistent and transparent approach to assessing integrated care boards (ICBs), NHS trusts and foundation trusts, ensuring public accountability for performance and providing a foundation for how NHS England will work with systems and providers to support improvement.

2. A draft of the framework was considered at the public meeting of the Board on 27 March, and it was agreed that the draft should be released for further engagement and consultation.

3. This paper provides a summary of the consultation responses and an overview of the new framework.

Consultation feedback

4. The consultation ran from 12 to 30 May. During the consultation period we also ran engagement sessions with ICB, and provider CEOs and Chairs facilitated by NHS Providers and NHS Confederation.  We also met with other stakeholders including National Voices and Healthwatch.

5. We received over 150 responses to the consultation online and by email, including from ICBs and trusts, and key stakeholders including representative bodies and patient advocacy groups.

6. Over 70% of respondents either agreed with or were neutral on the proposals outlined in the consultation documentation.

7. Annexed to this paper is a summary of the responses received which explains how these have been addressed in the final framework.

Overview of the new approach

8. The new framework describes a consistent and transparent approach to assessing ICBs and NHS trusts and foundation trusts, ensuring public accountability for performance and providing a foundation for how we will work with systems and providers to support improvement. It sets out how we will assess providers and ICBs, alongside a range of agreed metrics, promoting improvement while helping us identify quickly where organisations need support.

9. The framework is supported by a focused set of national priorities, including those set out in the planning guidance for 2025/26, aiming to strengthen local autonomy. These are presented alongside wider contextual metrics that reflect medium-term goals in areas such as inequalities and outcomes. The contextual metrics do not contribute to the segmentation score but will inform how NHS England responds to segmentation.

10. The NHS priorities and operational planning guidance 2025/26 made it clear that achieving a financial reset this year is a priority. The NHS must live within the budget it is allocated, reduce waste and increase productivity to deliver growth against demand. It set the expectation that every ICB and provider must deliver a balanced net system financial position in collaboration with its system partners, and we will identify organisations that are not performing and take timely action. Our approach to assessment will mean that unless providers are delivering a surplus or breakeven position, their segmentation will be limited to no better than segment 3.

11. Our improvement approach will be based on the results of our assessment and tailored to the support providers in each delivery segment need. Discussions about performance will be led by colleagues at NHS England who are experienced in addressing delivery challenges, with a focus on offering evidence-based insight and practical guidance that is grounded in a deep understanding of the operational challenges faced.

12. Our assessment will be the starting point for how we work with organisations throughout the year and will help us determine how we can support them to improve. We will do this by considering an organisation’s segment score, as set out in this framework, and leadership capability.

13. The framework outlines the circumstances in which providers can obtain increased freedoms. It also describes how we will determine whether a provider’s performance falls below an acceptable standard and/or has governance concerns that may lead NHS England to exercise its regulatory powers to step in and secure improvement.

14. We will not be segmenting ICBs in 2025/26, as this will be a year of significant change for ICBs as they transform in line with the Model ICB Blueprint to focus on strategic commissioning and implement plans to meet running cost reductions. Support for ICBs this year will focus on the safe implementation of their plans. ICBs that are currently in the Recovery Support Programme will continue in this programme and will be assessed against their current improvement trajectory to agree a transition plan. This will be equivalent to segment 5.

15. We will report ICB performance against the full suite of oversight metrics but not issue a comparative rating. ICBs will still be assessed through a statutory annual assessment, which reviews how well each ICB is discharging its statutory duties. Where there are performance or governance concerns, NHS England will step in, and we may use our regulatory powers to secure improvement. We will introduce the segmentation approach for ICBs in 2026/27.

Next steps

16. The first segments for trusts, the underpinning data for the segment and an overall score that shows their relative position to similar organisations will shortly be available in the NHS Oversight Dashboard.

18. The framework will be reviewed in 2026/27 to incorporate work to implement the ICB operating model and to take account of the ambitions and priorities in the 10 Year Health Plan.

Annex: summary of consultation responses

Assessment approach

We proposed: Each ICB and provider is placed in a segment from 1 to 4 based on its performance against short- and medium-term NHS priorities. There will be an additional segment 5 for those in most need of support.

Feedback: 70% of respondents either agreed or were neutral when asked if the new assessment approach is objective and consistent. We also received nearly one hundred individual comments on the proposals.

Many of the comments agreed with the proposal to simplify the framework and welcomed the use of more objective measures to ensure consistency. Some respondents felt the roles of NHS England and ICBs were still not clear enough and others questioned how the framework aligned with the future position of NHS England and ICBs given the changing operating context.

How we have responded: To support organisations in understanding expectations we have added further clarifications to the ICBs’ roles under the framework, which aligns with the direction set out in the draft model ICB blueprint. We have provided an illustrative example of how contractual management will work between an ICB and NHS England.

We will not be segmenting ICBs in 2025/26, as this will be a year of significant change for ICBs as they transform in line with the Model ICB Blueprint to focus on strategic commissioning and implement plans to meet running cost reductions. As this is a one-year framework, we will review the roles and responsibilities and will begin segmenting ICBs when the framework is updated for 2026/27.

Respondents raised the importance of public accountability and the need for system partners to have access to standardised data about services. Alongside the first segments in Q2 we will also release a public dashboard that will contain the segments and the data that underpins the decisions.

Capability

We proposed: Segmentation decisions are based solely on delivery against the performance metrics. The capability ratings we consulted on in 2024 no longer influence which segment an organisation is allocated but will be considered as part of NHS England’s improvement response.

Feedback: 88% either agreed or were neutral when asked about proposals for capability not influencing the segment of an organisation. Comments acknowledged that it was important to consider wider contextual information such as leadership capability assessments in our improvement response to ensure balance. However, as the approach to segmentation aimed to achieve more objectivity and transparency, it was appropriate that capability, a predominantly judgement-based method of assessment, would not be included.

How we have responded: As a result of strong agreement, segment scoring will not include capability ratings. However, we have set out in the framework that a view of capability will still be used to inform our response to segmentation, including when we identify providers for entry into the Provider Improvement Programme, which will provide support for our most challenged providers. 

System performance

We proposed: Providers will not have their scores adjusted to reflect wider system performance.  Segmentation will be based on delivery against the performance metrics in the framework.

Feedback: 87% either agreed or were neutral that ICB segmentation should consider system performance. Comments recognised that it was important at this stage to recognise the ICB role in ensuring that the services they contract meet the needs of the population but also recognised that roles were changing and this should be reviewed. Some respondents felt there should be wider accountability for other system partners including NHS trusts, primary care providers and local authorities.

How we have responded: Providers have an obligation under the NHS provider licence to co-operate with other NHS services, NHS bodies and local authorities and a statutory duty to consider the wider effect of their decisions on the system.

We agree that it is not appropriate to moderate provider scores based on the performance of other organisations in the same system, over whomthe provider has no control. This could disincentivise improvement and insufficiently recognise high performers.

Arranging healthcare services for their populations is a general function of all ICBs. Under the current commissioning and financial allocation arrangements, they remain responsible for arranging services that meet operational standards, so these tests of system performance are still important measures of ICB performance.

Financial override

We proposed: Any organisation reporting a financial deficit is limited to segment 3 (but may still be placed in segment 4 or 5).

Feedback: 69% either agreed or were neutral when asked whether segments 1 and 2 should be limited to those meeting surplus or break even this included agreement or strong agreement from 60% of trusts and ICBs.

Respondents were concerned that penalising organisations who were meeting their agreed financial plans would create a disincentive to set ambitious goals to improve, and – that the financial segment limit will mean a large number of organisations in need of support.

How we have responded: The NHS priorities and operational planning guidance 2025/26 made it clear that achieving a financial reset this year is a priority. The finance limit will be applied only to organisational finances and will not account for system performance. As part of our performance improvement approach, , for organisations meeting their agreed plans, we will not limit the segment of any organisation that has an annual plan to break even that includes an in-year deficit, as long as the plan is on track.

Organisations should submit ambitious but achievable plans; however, it is the case that organisations need to strive to reach financial balance. ICBs, trusts and primary care providers must work together to plan and deliver a balanced net system financial position in collaboration with other integrated care system (ICS) partners. This will require prioritisation of resources and stopping “lower-value activity” so we can say that setting the override at 3 is consistent with what we have set as a priority in the planning guidance.

Metrics for 2025/26

We proposed: Use of fewer metrics to calculate a segment decision based on critical priorities for 2025/26.

Feedback: 77% either agreed or were neutral when asked whether the proposed focused list of metrics will simplify the assessment approach and enable organisations to focus on operating priorities consistent with the reset agenda. We did receive some comments expressing concern about the risk of unintended consequences from having a narrower focus, however the majority of responses recognised the importance of simplifying the approach and allowing focus on the priorities in the short term to support the period of transformation for this year.

We also asked whether respondents had any concerns about the impact the overall framework might have on inequalities and received 88 responses mostly focused on the metrics list. 26% of these comments were concerned that NHS England may be considering no longer measuring progress against reducing inequalities and 14% were concerned that not including inequalities measures would cause reduced attention on this area.

How we have responded: Considering the need to focus on a reduced set of priorities for this transitional year, and with the support of the consultation respondents, we have adopted the shorter metric list as the basis for segmentation scoring. However, we have made some amendments to the contents of this list and the way it is displayed in the framework.

The move to a focused metric list is consistent with the move to a simpler NHS operating model which will be rules-based and provides clarity on responsibilities and priorities, the metrics are referred to as scoring metrics in the new framework. As part of our selection of these metrics NHS England’s clinical executives considered the measures for quality of care, to ensure that these reflect a balanced view across experience, safety and effectiveness of care.

Reducing health inequalities remains a key priority for NHS England and we will continue to collect and review when co-ordinating our segmentation response. We call these contextual metrics in the framework and the data will be publicly available in the framework dashboard when it is launched in Q2. Many of these measures are also included as essential data for boards to monitor in our Insightful Board documents where the importance of how boards use this information is explained.

Reducing health inequalities is a statutory duty for ICBs and will therefore be considered as part of their annual ICB assessments which will be discussed as part of performance improvement consultations.

The framework will be reviewed in 2026/27 to incorporate work undertaken to implement the ICB operating model and to take account of the ambitions and priorities in the 10 Year Health Plan.

Other changes and general comments

We received 62 suggestions for new metrics, ranging from measures of patient or workforce experience, to measures of outcomes for patient groups such as children and young people. Due to the need to focus on fewer priorities for this year, we have not adopted these additional metrics, however we will review these responses when the framework is updated for 2026/27 and will consider whether they should be adopted as part of the approach. We are grateful for the stakeholders who offered to support us in further developing some of these metrics in the future.

Considering the changing operational context, we have also made some further changes to the framework which were not influenced by the consultation. The proposal is that we will undertake a diagnostic of all organisations who are in segment four to determine entry into the Recovery Support Programme will be replaced by a more flexible approach, the Provider Improvement Programme, entry to which will be decided based on segmentation and capability. We have also provided some further detail on how NHS England will respond to segmentation.

Publication reference: Public Board paper (BM/25/31(Pu))