Protocol for organisational change transitions

100. We accept this recommendation. We agree that these are important concepts, and indeed a number of protocols were drawn up and widely communicated in managing changes to the health system in 2012. The Department of Health issued guidance to NHS bodies in transition in September 2011 setting out the effective management of records during organisational change22. 101. In its report of 10 July 2013, "Managing the transition to the reformed health system"23 the National Audit Office noted the "considerable planning and preparatory work" that was done ahead of the Health and Social Care Act being passed and highlighted that the "Department's programme management demonstrated many elements of good practice"24, including comprehensive governance structures, ongoing monitoring arrangements for key aspects of the transition, and a variety of mechanisms to assess and gain assurance about the new system's state of readiness. 102. The National Archives has oversight of records management within Government departments, and publishes guidance on best practice. They have recently revised the guidance on "Machinery of Government Changes"25 which the Department follows when transferring information assets between owners. The National Archives have considered the Department's records management compliance as part of their Information Management Assessment in October 2014, the report of which will be published shortly.

The Thirlwall Inquiry has noted action taken in response to this recommendation.

The Records Management Code of Practice for Health and Social Care 2016 sets out what people working with or in NHS organisations in England need to do to manage records correctly. It is based on current legal requirements and professional best practice and was published on 20 July 2016 by the Information Governance Alliance (IGA). The Code of Practice was updated in 2021.

The DHSC revised and published its Information Management Policy in April 2018.

NHS England has carried out a significant programme of work to ensure the risks of transfer have been addressed in the reorganisation of programmes, particularly at system level, through published guidance.

The Records Management Code of Practice for Health and Social Care 2016 sets out what people working with or in NHS organisations in England need to do to manage records correctly. It is based on current legal requirements and professional best practice and was published on 20 July 2016 by the Information Governance Alliance (IGA).

The Department revised and published its Information Management Policy in April 2018.

Since the publication of the Morecambe Bay Investigation, the Department and the National Health Service have put in place a number of measures that are designed to ensure that organisational change is well managed.
These include arrangements to support local integration of services and strengthened regional support and oversight. The NHS has also developed a Long Term Plan to provide clear strategic direction to organisations making local changes.
NHS England and NHS Improvement are responsible for ensuring that organisational changes such as the merger of provider organisations are in the interests of patients and taxpayers and manage any risks effectively.

Department of Health response (July 2015): Accepted. “The Department of Health issued guidance to NHS bodies in transition in September 2011 setting out the effective management of records during organisational change.

National Archives has oversight of records management within Government departments and publishes guidance on best practice. They have recently revised the guidance on “Machinery of Government Changes” which the Department follows when transferring information assets between owners.

The National Archives have considered the Department’s records management compliance as part of their Information Management Assessment in October 2014, the report of which will be published shortly.” (p. 91-92)