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ICB Engagement Evidence  ·  Status: ON RECORD  ·  Challenge to ICB engagement claims under s14Z45
ICB Engagement Evidence NHS Devon Integrated Care Board
ON RECORD

Challenge to NHS Devon ICB's Claims of Public Engagement on the One Plan for Devon

ICB response to Dr Phil Keeling: 15 May 2026 | Campaign challenge: 4 June 2026 | No further response received
Why This Matters: NHS Devon ICB has repeatedly stated that it undertook "significant engagement", "co-development", and "working with communities" in developing the Devon Health and Care Strategy and the One Plan for Devon. The campaign's concern is that these are assertions unsupported by evidence: no dates, locations, methodology, participant numbers, or demographic data have been provided, and there is no evidence the engagement specifically addressed the One Plan for Devon as opposed to the separate national NHS 10 Year Plan. Under Section 14Z45 of the NHS Act 2006, ICBs have a legal duty to involve the public in planning commissioning arrangements. This thread tests whether that duty has been discharged with evidence or only with language.
The Conflation Concern: The ICB's 15 May response states that engagement undertaken for the national NHS 10 Year Plan "helped to shape" the Devon strategy and One Plan. The campaign argues this conflates two different things. A person consulted on national NHS priorities is not necessarily commenting on Torbay Hospital, Derriford, RDE, service relocation, or local emergency pathways. Treating national engagement as evidence of local engagement does not satisfy the ICB's local involvement duty under Section 14Z45.
The Cancelled Public Meeting: The ICB had confirmed that Chris Reid (Chief Place and Transformation / Chief Medical Officer for NHS Cornwall, Isles of Scilly and Devon ICB) would attend a public meeting on 13 April 2026. The meeting was cancelled by the ICB shortly before the event, citing NHS pre-election restrictions. The campaign notes that Torbay had no local elections, that the ICB has not identified the specific guidance clause that prevented attendance, and that no alternative date was offered at the time.

Parties:

  • Dr Phil Keeling (Heart Campaign Committee) submitted the original questions
  • NHS Devon ICB communications and engagement team responded on 15 May 2026
  • Susie Colley (Campaign Chair) issued the substantive challenge on 4 June 2026
  • The ICB offered a Microsoft Teams meeting with Chris Reid on 12, 19, or 26 June 2026

The campaign's eight areas of challenge (4 June 2026):

  1. "We undertook significant engagement": the phrase is unsupported by dates, locations, methodology, participant numbers, or demographics. The campaign asks for a full schedule of engagement activities and the complete engagement dataset.
  2. Reliance on the national 10 Year Plan engagement: the campaign asks how engagement on a national NHS policy process can count as engagement on local Devon service transformation, and what local engagement was undertaken specifically on the One Plan. If none, how the ICB satisfied its Section 14Z45 duty.
  3. The timing issue: the formal commencement date of the One Plan, what actions have already been undertaken and funded, which commenced before publication, and what public engagement took place before those actions commenced.
  4. Cancellation of the public meeting: the specific pre-election guidance clause relied upon, why attendance was agreed and then cancelled two days beforehand, why no replacement date was offered, and copies of internal correspondence on the cancellation.
  5. Consultant recruitment: whether the ICB has assessed if recruitment is being affected by uncertainty over future service configuration, and whether it has received recruitment-concern reports from the three Trusts.
  6. "No specific decisions about individual hospital services": if no decisions have been made, what options are under consideration, whether any modelling or options appraisals have been completed, and which hospital services are under review.
  7. The People and Communities Framework: citing the framework is not evidence the duty was discharged. The campaign asks for Equality Impact Assessments, Public Involvement Impact Assessments, engagement plans, stakeholder maps, participation reports, and Governing Body papers.
  8. The missing data: the campaign asks for written evidence to support every engagement claim, since without it terms such as "significant engagement", "co-developed", and "public involvement" remain assertions rather than demonstrable facts.

From: Susie Colley (chair@tqcc.co.uk)
To: NHS Devon ICB Involve team
CC: Dr Phil Keeling (Heart Campaign Committee), Cat Johns (Torbay Council)

Good afternoon NHS Devon communications and engagement team.

As Chair of the Heart Campaign I have read the reply sent to Dr Phil Keeling, who is part of the Heart Campaign Committee, and it is my opinion that the majority of the responses contain a number of assertions, references to engagement, and statements of intent, but relatively little evidence.

I am concerned that throughout the responses there are repeated references to "significant engagement", "co-development", "opportunities to get involved", and "working with communities", but almost no detail about: who was engaged; when they were engaged; how they were selected; how many people participated; what data was collected; how the findings influenced the final strategy; and why no specific Devon-wide public meetings appear to have taken place before publication.

1. "We undertook significant engagement" No dates, locations, methodology, numbers, or demographic breakdown are given, and no evidence is provided that the engagement specifically addressed the One Plan for Devon or that Torbay residents participated. Please provide a schedule of all engagement activities with date, location, format, number of participants, organisation responsible, and whether attendance was open to the public; the full engagement dataset; and the evidence trail showing how public feedback altered the final documents.

2. Reliance upon NHS England's 10-Year Plan Engagement Were people consulted on the national NHS plan or on Devon service changes? These are not the same thing. Please explain how national engagement can be regarded as engagement regarding service transformation in Devon, what specific local engagement was undertaken solely on the One Plan, and, if none, how the ICB satisfied its Section 14Z45 duty.

3. The Timing Issue When did implementation begin? Please supply the formal commencement date of the One Plan, what actions have already been undertaken and funded, which commenced prior to publication, and what public engagement took place before those actions commenced.

4. Cancellation of the Public Meeting Chris Reid had been invited and the ICB confirmed he would attend a public meeting on 13 April. The meeting was cancelled shortly before the event, citing pre-election restrictions. However, Torbay had no local elections. Please provide the specific NHS pre-election guidance relied upon, the clause that prevented attendance, why attendance was agreed and then cancelled only two days before, why no replacement date was offered, and copies of internal correspondence relating to the cancellation.

5. The Consultant Recruitment Issue The question was whether the ICB would investigate concerns that consultants are advising trainees not to apply to Torbay Hospital because of perceived future downgrading. Has the ICB assessed whether workforce recruitment is being affected by uncertainty regarding future service configuration, and has it received reports from the three Trusts?

6. "No Specific Decisions About Individual Hospital Services" If no decisions have been made, what options are under consideration? Has the ICB undertaken any modelling of future service distribution? Have any options appraisals been completed? Which hospital services are currently under review?

7. The "People and Communities Framework" Merely citing legislation is not evidence the duty has been fulfilled. Please provide Equality Impact Assessments, Public Involvement Impact Assessments, engagement plans, stakeholder maps, participation reports, and Governing Body papers discussing engagement.

8. The Missing Data Without written evidence, terms such as significant engagement, co-developed, and public involvement remain assertions. Please provide a complete schedule of all engagement activities, copies of surveys and consultation materials, the raw and analysed engagement data, and evidence showing how feedback influenced the final plans.

Kindest regards

Susie Colley
Chair of the Torquay Chamber of Commerce and the Heart Campaign
(Declined) Governor of Torbay Hospital

From: INVOLVE (NHS Devon ICB) d-icb.involve@nhs.net
To: Dr Phil Keeling
CC: Susie Colley (chair@tqcc.co.uk)
Subject: RE: Meeting - 13 April 2026

Dear Phil,

Thank you for your emails dated 14 April 2026 and 22 April 2026. To ensure each of your questions are responded to directly, your questions are highlighted in bold below followed by our response.

1. Has the ICB got a plan to get management AND CLINICIANS together to work on the practicalities of improving healthcare over the next 2 decades? Yes, we have recently published our Health and Care Strategy and One Plan for Devon, our Five-year commissioning plan. Our future plans align fully with the published NHS 10 year plan.

2. Has the ICB got a timeline to explain the 5y plan to the public? How can we be 12m into this plan before it has been published and undergone ANY public engagement? We undertook significant engagement as part of the 10 Year Plan development. This helped to shape the development of the health and care strategy and the One Plan for Devon. The findings from the 10 Year Plan engagement are referenced in both documents. In line with national NHS pre-election guidance, we were limited in attending public meetings up until 7 May 2026. However, we will be engaging openly with local communities over the summer in collaboration with Healthwatch.

3. Can the ICB comment and investigate what is being said by consultant staff at both RDE and Derriford advising trainee doctors NOT TO APPLY for jobs at TBH? Operational matters, including recruitment, supervision and advice given to trainee doctors, are led by individual NHS Trusts and managed through their own clinical, workforce and governance arrangements. We take concerns about workforce confidence and recruitment seriously. While this would be a matter for the relevant Trusts to address directly, we will share this feedback with the ICB workforce team.

The One Plan for Devon sets out the overall direction for health and care over the next five years. It does not include specific decisions about individual hospital services but does recognise that delivering sustainable services across Devon will not be possible without transformation.

ICBs and trusts all have legal duties to involve the public, outlined in the One Devon People and Communities Framework. The main duties are set out in the National Health Service Act 2006, as amended by the Health and Care Act 2022: section 13Q for NHS England, section 14Z45 for integrated care boards, and section 242(1B) for NHS trusts and foundation trusts.

We would like to offer you a meeting on MS Teams with Chris Reid, Chief Place and Transformation / Chief Medical Officer, supported by the Director of experience and engagement. Convenient dates offered: 12 June 9.00-10.00; 19 June 12.15-1.00; 26 June 9.00-10.00.

Kind regards
NHS Devon communications and engagement team

Status

The thread runs from Dr Phil Keeling's questions of 14 and 22 April 2026, to the ICB's response of 15 May 2026 (asserting "significant engagement" but providing little supporting evidence, attributing engagement largely to the national NHS 10 Year Plan, and offering a Teams meeting with Chris Reid), to the campaign's challenge of 4 June 2026 setting out eight areas where the response relies on assertion rather than evidence. The campaign is pressing the ICB to evidence its public involvement duty under Section 14Z45 with documents rather than language. A Teams meeting with Chris Reid has been offered for June. No written evidence schedule has yet been provided. If the ICB does not produce the underlying engagement records, the matters raised could be converted into formal FOI requests.

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