This information refers to technical decisions around (i) when an integrated care board (ICB) appoints a responsible officer and takes on designated body status under the Responsible Officer Regulations (amended 2013) (‘the regulations’), and (ii) when determining where a doctor, who works for more than one designated body, should connect.

ICB designated body status

The regulations set out that a health care organisation must nominate a responsible officer when the organisation engages or contracts with a doctor without a prescribed connection elsewhere. There can arise a scenario in an organisation where the only doctor without a connection is the doctor nominated as the responsible officer, e.g. the Chief Medical Officer of an ICB. As responsible officer they then connect to their Higher Level Responsible Officer but do not have any doctors with a prescribed connection to them.

Custom and practice in NHS England is that organisations in this situation should nevertheless nominate their responsible officer and engage with their status as a designated body. Doing so opens the channels of support available to the responsible officer from the HLRO and their team. It also allows the body to make full use of the regulations in promoting professional standards across the whole of their quality and professional governance framework. It is especially helpful when, over time, the ICB engages or contracts with doctors, whether connected to the ICB or to other designated bodies.

Colleagues in ICBs are reminded that the intention behind the regulations is to underpin good processes around professional standards. All healthcare bodies have a duty to undertake due diligence in clinical governance regardless of designated body status; indeed excellence in this area is a key foundation in the pursuit of high quality care for patients.

Prescribed connection for a doctor working for more than one designated body

If a doctor is on the NHS England Medical Performers list (PL), their prescribed connection is always to NHS England even if they do more work for another organisation. Where a doctor is not on the PL they will connect to the designated body for which they carry out most of their work. Where the doctor does equal amounts of work between a number of designated bodies, the connection will be to the body closest to their GMC registered address.

For the purpose of this decision the regulations do not distinguish or prioritise one form of work over another e.g. clinical vs managerial.

This information sheet is relevant to NHS England regions and the Integrated Care Boards aligned to them. It should be read in conjunction with Sheet 47a: Professional standards in ICBs: Principles.