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Independent review

Infected Blood Compensation Authority Independent Review

Completed
Sir Tyrone Urch and Hazel Hobbs · Published 30 October 2025 · Commissioned by Infected Blood Compensation Authority

This is a link to an independent review of the Infected Blood Compensation Authority commissioned by the Cabinet Office.

Government Response

Holding statement only. The Cabinet Office commissioned this internal assurance review of IBCA's delivery (by Sir Tyrone Urch). The Paymaster General published it on 30 October 2025, deposited it in both Houses, and undertook to consider its recommendations; no formal point-by-point government response to the 24 recommendations was issued.

Recommendations

Recommendation 1
Infected Blood Compensation Authority
21. Cross-government support. This has been absolutely critical to date and the RT noted several excellent examples of early support from His Majesty’s Revenue and Customs (HMRC), Department for Work and Pensions (DWP) and Ministry of Justice (MOJ). Greater cross-government support is absolutely required right now from the NHS and, to a lesser degree, other organisations if the rate of evidence gathering is not to act as a “fundamental progress handbrake” when multiple cohort complexities are being dealt with next year. Other departments and organisations could also provide further support (e.g. DWP - for debt management and potentially the loan of staff experienced in developing operational policy, guidance and issue resolution; National Economic Crime Centre (NECC) - a senior level introduction here would be helpful). a. Priority 1 - NHS. The RT was made aware of particular pinch-points that have arisen for claims awaiting resolution, but that these are currently grouped in a few specific centres of expertise. If agreement could be reached so that the NHS prioritised the provision of medical evidence for victims, this would immediately cut a backlog of extant claims, including some in the ‘end of life’ priority category. Looking ahead, this becomes more of a concern, due to resourcing limitations, case complexity, and the need for additional expert clinical input. This, and associated escalation protocols in the Department of Health and Social Care (DHSC) and the Devolved Administrations (DAs) must be resolved before multiple cohort cases arrive next year. The loan of clinical and/or clerical support to the NHS to find data evidence could prove hugely beneficial, as it was during the Covid pandemic. What additional specific support do the DHSC, NHS and DAs require to provide more timely support?
Recommendation 2
Infected Blood Compensation Authority
22. A plan for the future. There is a step change in process complexity and volume coming next year but there has been little IBCA bandwidth available to engage with this up until now; a commonplace comment was “we don’t understand the plan to get there”. A re-focus on effective and integrated planning needs to become IBCA’s priority following their successful operational delivery mission in 2025. The multi-dimensional concurrent nature of what is coming (e.g. complicated eligibility policy, multiple cohorts, a step change in the range of external dependencies, requirement to actively search out evidence, dealing with disputes, new regulations, revisiting existing paid claims, messaging) needs to be addressed as a matter of urgency.
Recommendation 3
Infected Blood Compensation Authority
23. Digital and data delivery. Delivery to date has been based on a largely manual operation with tactical IT tooling, whilst work was progressed to design a bespoke claims system to meet the needs of IBCA users. Whilst this was acceptable for the initial cohort with a pre-existing evidence history and past interim payments, it is not considered scalable by anyone the RT interviewed for all of the future cohorts, where significant policy unknowns, evidence gaps and fraud threats will emerge. Development of a more secure and efficient digital and data platform has been the “biggest brake” to date on delivery scaling. The RT found that the volume of policy and other changes have been “running ahead of the ability of technical build to keep up”, with a period of constantly changing priorities. The RT also heard a lack of clarity across different teams in IBCA on what functionality is being developed and how it will be integrated into a user journey that will retain many human elements, rather than a “faceless” digital claim. Nonetheless substantive progress has been made and there are green shoots of more stable planning. What the IBCA team is asking for most here is stability and certainty in their direction. Four key headlines with a subjective delivery assessment are below:
Recommendation 4
Infected Blood Compensation Authority
24. Compelling clear narrative. There is much to be gained from developing a more proactive internal and external narrative that is fully open and transparent; summarised as a requirement for “more engagement and less comms”. A braver externally-facing engagement approach is required if the current community goodwill amongst cohort one is not to be lost. It is, however, acknowledged that there is an accentuated risk of working more in the open, particularly when baseline research from early 2025 shows “a third trust us, a third don’t, a third don’t know”. Investment in intensive outreach and engagement with support groups and societies, who play a vital role in supporting victims and helping to identify and resolve issues, should continue and will be pivotal to deliver further momentum.
Recommendation 5
Infected Blood Compensation Authority
25. Resourcing. There are a large number of specialist personnel that must / should / could be recruited to support the way IBCA needs to evolve going forward. These requirements are covered in detail at Question 6 later, but additional legal and independent finance support is an immediate priority and essential to community confidence and the efficient processing of claims. One of the key lessons from other compensation schemes the RT spoke to was the vital importance of efficient and constructive channels of communication with longstanding legal representatives, whilst managing any adverse behaviours and the commercial incentive structures robustly.
Recommendation 6
Infected Blood Compensation Authority
Contract now for the legal and financial support required to cope with the incoming parallel multi-cohort demand, with appropriate commercial levers and review points.
Recommendation 7
Infected Blood Compensation Authority
Determine which Association for Project Management (APM) project delivery principles would enhance productivity.
Recommendation 8
Infected Blood Compensation Authority
29. Lessons identified. The RT cannot confirm if all the internal and external (e.g. Infected Blood Inquiry, Horizon, Windrush, Grenfell) lessons have been identified, captured, deposited and learned. The RT received feedback for example that “more could be done to illustrate what has been learned and incorporated into the scaling of payments to registered infected”. There are routine engagement opportunities with claim stakeholders, MPs and Parliamentary groups and these must continue to grow. The RT commends the importance of finding some independent capacity to capture the learnings and lessons from IBCA across delivery phases, including the outgoing CO programme team, before that insight is lost or fades from memory.
Recommendation 9
Infected Blood Compensation Authority
Ensure all the on-going internal lessons, and those identified from other government compensation schemes, have been captured by a responsible owner in a live, widely-available database that is updated and used regularly.
Recommendation 10
Infected Blood Compensation Authority
Accelerate the resourcing required for a governance reset, including Board capacity and an experienced company secretary.
Recommendation 11
Infected Blood Compensation Authority
Establish capacity for more robust red team challenge, critical friend support, and SLT mentoring.
Recommendation 12
Infected Blood Compensation Authority
Develop a live strategic risk register to focus energy on the medium and longer term strategic decisions.
Recommendation 13
Infected Blood Compensation Authority
Decide how to mature the business critical forecast model and quality assure key assumptions.
Recommendation 14
Infected Blood Compensation Authority
Develop a more coordinated and robust assurance plan against the principal risks.
Recommendation 15
Infected Blood Compensation Authority
Retain continuity of CO Chief Financial Officer insight and oversight via attendance at the IBCA Audit and Risk Assurance Committee.
Recommendation 16
Infected Blood Compensation Authority
Develop a balanced scorecard of key performance measures for transparent reporting to the IBCA Board and CO Sponsor.
Recommendation 17
Infected Blood Compensation Authority
Introduce a bolder and more agile approach to CO decision-making approvals and release the burden of lower threshold cost controls.
Recommendation 18
Infected Blood Compensation Authority
Review the required skill set for an empowered and experienced sponsor in this specific operating environment.
Recommendation 19
Infected Blood Compensation Authority
Continue to reach-back into CO and wider government back office services and centres of expertise where this does not impact on operational or decision making independence.
Recommendation 20
Infected Blood Compensation Authority
Decide which of the resource requirements above must, should or could be actioned with more speed and flexibility on the reward offer to create the conditions for success next year.
Recommendation 21
Infected Blood Compensation Authority
Empower the incoming HR Director to provide bespoke people reward and recognition strategies, drawing on best practice outside government.
Recommendation 22
Infected Blood Compensation Authority
Implement comprehensive personnel resilience measures to support a high quality workforce that is going to become increasingly tired.
Recommendation 23
Infected Blood Compensation Authority
Review systems and ways of working for continuous feedback loops between CO and IBCA operational, policy and legal teams for the next phase of delivery.
Recommendation 24
Infected Blood Compensation Authority
Establish a joint IBCA/CO/DHSC workstream for IBSS transfer to include a dedicated project manager, senior cross-nation governance, regular ministerial focus and user input.
No recommendations with this response.